corresp
March 22, 2011
By EDGAR Submission
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Mail Stop 4561
Washington, DC 20549
Attention: Jaime John
Re: |
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Amdocs Limited
Form 20-F for the Fiscal Year Ended September 30, 2010
Filed December 7, 2010
File No. 001-14840
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Ladies and Gentlemen:
On behalf of Amdocs Limited (the Company), please find below an acknowledgment of the
Company as requested by the Staff (the Staff) of the U.S. Securities and Exchange Commission (the
Commission) in the letter dated January 26, 2011 from Patrick Gilmore, Accounting Branch Chief,
of the U.S. Securities and Exchange Commission (the Commission), to Thomas G. OBrien, Treasurer
and Secretary of Amdocs.
In the comment letter, the Staff requested that the Company acknowledge certain matters with
respect to the filing. Specifically, the Staff provided the following comment:
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange
Act of 1934 and applicable Exchange Act rules require. Since the company and its management
are in possession of all facts relating to a companys disclosure, they are responsible for
the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
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the company is responsible for the adequacy and accuracy of the
disclosure in the filing; |
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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 |
U.S. Securities and Exchange Commission
March 22, 2011
Page 2
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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. |
By this letter, the Company hereby acknowledges that:
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the Company is responsible for the adequacy and accuracy of the
disclosure in the filing; |
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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 |
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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. |
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U.S. Securities and Exchange Commission
March 22, 2011
Page 3
Please do not hesitate to contact the undersigned at 314-212-8383 with any questions regarding this
response letter or the above acknowledgement.
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Very truly yours,
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/s/ Thomas G. OBrien
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Thomas G. OBrien |
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Secretary and Treasurer |
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