SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

      							March 22, 2005

Mail Stop 0406

Mr. Joseph L. Mullen
Chief Executive Officer
Bottomline Technologies (de), Inc.
325 Corporate Drive
Portsmouth, New Hampshire 03801

RE:	Form 10-K for the fiscal year ended June 30, 2004
		Form 10-Q for the fiscal quarter ended September 30,
2004
      Form 10-Q for the fiscal quarter ended December 31, 2004
      File No. 000-25259

Dear Mr. Mullen:

		We reviewed your response letter dated March 16, 2005
and
have the following additional comments.  Please note that we have
limited the scope of our review to certain accounting policies and
practices in your financial statements and related disclosures.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Annual Report on Form 10-K for the Year Ended June 30, 2004

Item 6.  Selected Financial Data, page 9

Prior Comment No. 3

1. Provide us with your revised disclosure of the usefulness of
your
non-GAAP financial measures.  Ensure your disclosure clarifies the
material limitations associated with the use of your non-GAAP
financial measures and does not indicate that you believe that the
non-GAAP measures are more accurate than the most directly
comparable
GAAP measure.

Quarterly Report on Form 10-K for the Quarter Ended September 30,
2004

Note 6. Operations by Segments and Geographic Area, page 5

Prior Comment No. 5

2. Your response to prior comment number 5 indicates that you
tracked
financial data across multiple segments beginning in the year
ended
June 30, 2004.  Since it is not impracticable for you to recast
your
segment disclosures for the year ended June 30, 2004, we believe
you
should present recast reportable segment disclosures for this
annual
period and disclose that it is impracticable to present this
information for prior financial periods.  Tell us why you did not
present this segment information as of June 30, 2004, considering
that the financial data was being tracked.  Indicate when the
segment
information began to be regularly evaluated by your chief
operating
decision maker.  Refer to paragraph 10 of SFAS 131.

Please respond to these comments within 10 business days and file
your response letter via EDGAR.  Please understand that we may
have
additional comments after reviewing your responses to our
comments.

You may contact Christopher White, Staff Accountant, at (202) 942-
8645, Melissa Walsh, Senior Staff Accountant, at (202) 942-1822 or
me
at (202) 942-2949 if you have any questions regarding these
comments.

							Very truly yours,

							Craig Wilson
							Senior Assistant Chief
Accountant

??

??

??

??

Bottomline Technologies (de), Inc.
March 22, 2005
page 1

</TEXT>
</DOCUMENT>