Room 4561

	August 19, 2005

Mr. Thomas G. O`Brien, Esq.
Treasurer
Amdocs Limited
1390 Timberlake Manor Parkway
Chesterfield, Missouri 63017

Re:	Amdocs Limited
	Post-effective Amendment No. 7 to Registration Statement on
Form
F-3
	Filed August 16, 2005
	File No. 333-114344

Dear Mr. O`Brien:

      We have limited our review of your filings to those issues
we
have addressed in our comments.  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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Selling Securityholders

1. Please disclose whether any added selling securityholder is a
registered broker-dealer.  We note that you added PIMCO
Convertible
Fund and UBS Securities LLC as selling securityholders.  If a
selling
securityholder is a registered broker-dealer, please identify such
registered broker-dealer as an underwriter in your disclosure,
unless
the shares were acquired as transaction-based compensation for
investment-banking services.  Provide a description of the
investment-banking services and the manner in which the
compensation
for the services was computed, as applicable.

2. Please disclose whether any added selling securityholder is an
affiliate of a registered broker-dealer.  If a selling
securityholder
is an affiliate of a registered broker-dealer, please expand the
prospectus to indicate whether such selling stockholder acquired
the
securities to be resold in the ordinary course of business.  Also
indicate whether at the time of the acquisition such selling
stockholder had any agreements, understandings or arrangements
with
any other persons, either directly or indirectly, to dispose of
the
securities.


*              *              *              *

      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 filings to be certain that the
filing includes all information required under the Securities Act
and
that they have provided all information investors require for an
informed investment 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.

      Prior to our declaration of the effective date of the
pending
post-effective amendment pursuant to Section 8(c) of the
Securities
Act, the company should furnish a letter acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert the staff comments and the
declaration
of effectiveness 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.

      You may contact Daniel Lee at (202) 551-3477 with any
questions.  If you need further assistance, you may contact me at
(202) 551-3462 or Barbara C. Jacobs, Assistant Director, at (202)
551-3730.


							Sincerely,


							Mark P. Shuman
							Branch Chief - Legal

cc:	Via Facsimile

	Mr. Robert A. Schwed, Esq.
	Wilmer Cutler Pickering Hale and Dorr LLP
	399 Park Avenue
	New York, New York 10022
	Telephone: (212) 230-8800
	Facsimile:  (212) 230-8888