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WILMER CUTLER PICKERING
  HALE AND DORR LLP

                                                 Robert A. Schwed

                                                 399 PARK AVENUE
                                                 NEW YORK, NY 10022
                                                 +1 212 937 7276
                                                 +1 212 230 8888 fax
                                                 robert.schwed@wilmerhale.com


August 29, 2005

Via Edgar

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention: Daniel Lee

Re:  AMDOCS LIMITED
     Post-Effective Amendment No. 7 to Registration Statement on Form F-3
     File No. 333-114344
     Filed on August 16, 2005
     ------------------------

Ladies and Gentlemen:

On behalf of our client Amdocs Limited ("Amdocs" or the "Company"), we are
submitting the following responses of the Company to the legal comments of the
staff (the "Staff") of the Securities and Exchange Commission (the "SEC") set
forth in a letter dated August 19, 2005, from Mr. Mark Shuman, Branch Chief -
Legal, of the Division of Corporation Finance of the SEC. The comment letter
relates to Post-Effective Amendment No. 7 to Registration Statement on Form F-3
(File No. 333-114344) filed by the Company with the SEC on August 16, 2005 (the
"Post-Effective Amendment").

For convenient reference, we have included below each of the Staff's comments
set forth in the comment letter and have keyed the Company's responses to the
numbering of the comments and the headings used in the comment letter. Each of
the responses are based on information provided to us by the selling
securityholders named in the Post-Effective Amendment.

The Company is filing herewith Amendment No. 1 to the Post-Effective Amendment
("Amendment No. 1"). Where appropriate, the Company has responded to the Staff's
comments by making changes to the disclosure in the Registration Statement set
forth in Amendment No. 1. Page numbers referred to in the responses reference
the applicable pages of Amendment No. 1.

The Company believes that Amendment No. 1 is responsive to the Staff's comments
and, accordingly, is filing herewith an acceleration request that the Form F-3
be declared effective as promptly as possible.

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


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Securities and Exchange Commission
August 29, 2005
Page 2


          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.

Response:      The Company has been informed by UBS Securities LLC that it is a
               registered broker-dealer. In response to the Staff's comment, the
               Company has included this disclosure on pages 59 through 60 of
               Amendment No. 1. The Company has been informed by PIMCO
               Convertible Fund that it is not a registered broker-dealer.

     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.

Response:      The Company has been informed by PIMCO Convertible Fund that it
               is not an affiliate of a registered broker-dealer.

Please do not hesitate to contact the undersigned (212-937-7276) or Jason L.
Kropp (617-526-6421) of this firm with any questions regarding this response
letter.

Very truly yours,

/s/ Robert A. Schwed

Robert A. Schwed

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