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December 17, 2004

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington D.C.
20549

  Attn:

  Linda van Doorn

  William Demarest

  Re:

  Watson Wyatt & Company Holdings

  File No. 001-16159

  Form 10-K for the year ended June 30, 2004

  Form 10-Q for the quarterly period ended September 30,
  2004

Dear Ms. Doorn and Mr. Demarest:

We are submitting this letter in response to your letter,
dated December 16, 2004, to Carl Mautz, Chief Financial Officer of Watson Wyatt
& Company Holdings (the Company).
The response set forth below corresponds to the numbered paragraph in
your letter.

In connection with our response, we acknowledge the
following:

•                  The Company is responsible for the adequacy and accuracy of the disclosure
in the filing;

•                  Staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission  from taking
any action with respect to the filing; and

•                  The Company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.

Notes to Consolidated Financial Statements

Note 16 - Discontinued Operations

1.              Related to prior comment 6, expand your disclosure in future filings to
include the information contained in your response.  Please confirm to us that you will expand
your disclosure.

We will
expand our disclosure in future filings to include the information provided in
response to prior comment 6.

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We
believe we have addressed all of your comments.
Please contact me at (202) 715-7056 if you wish to discuss any of our
responses.

Very
Truly Yours,

Carl
D. Mautz

Chief
Financial Officer

Watson
Wyatt and Company Holdings

  cc:

  Brian
  Lane, Esq.

  Walter
  W. Bardenwerper, Esq.

  Hong
  Nguyen, Esq.

  Peter
  L. Childs, Controller

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