SecProbe.io

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      Mail Stop 4561

								October 17, 2005

William D. Green
Chief Executive Officer of Accenture Ltd.
General Partner of Accenture SCA
46A, Avenue of J.F. Kennedy
L-1855 Luxembourg

Re:	Accenture SCA
	Information Statement on Schedule 14C
	Filed October 7, 2005
	File No. 0-49713

Dear Mr. Green:

	This is to advise you that we have conducted only a limited
review of your information statement.  Based on that limited
review,
we have the following comments.
General

We note that Accenture Ltd. has nominated three individuals to
serve
on your Supervisory Board.  Please revise your information
statement
to include the information required by Item 7 and 8 of Schedule
14A
or tell us why you believe you are not required to do so.

*  *  *  *

      As appropriate, please amend your filing in response to
these
comments.  You may wish to provide us with marked copies of the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested supplemental information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your amendment and responses
to
our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing(s) to be certain that
they
have provided all information investors require for an informed
decision.  Since the company and its management are in possession
of
all facts relating to a company`s disclosure, they are responsible
for the accuracy and adequacy of the disclosures they have made.
Additionally, the registrant should provide written
acknowledgement
of the following:
* The adequacy and accuracy of the disclosure in the filing is the
responsibility of the registrant.
* The registrant acknowledges that staff comment or changes in
response to staff comment in the proposed disclosure in the
preliminary proxy materials do not foreclose the Commission from
taking any action with respect to the filing.
* The registrant also represents that staff comment may not be
asserted as a defense in any proceeding initiated by the
Commission
or any person under the federal securities laws of the United
States.
	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

	If you have any questions, please call Jeffrey Shady at (202)
551-3471 or me at (202) 551-3694.

      Sincerely,

      Owen Pinkerton
      Senior Counsel

cc:	Michael E. Hughes, Esq. (via fax)

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William D. Green
Accenture SCA
October 17, 2005
Page 2

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