March 31, 2005

Mail Stop 04-09

Mr. Douglas G. Scrivner, General Counsel and Secretary
Accenture Ltd
Canon`s Court
22 Victoria Street
Hamilton HM 12 Bermuda

RE:	Accenture SCA
            File No.  0-49713
	Form 10-K for the year ended August 31, 2004
Form 10-Q for the quarter ended November 30, 2004

Dear Mr. Scrivner:

We have reviewed the above referenced filings and have the
following
comments.  We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents.  As such, all persons who are responsible for the
adequacy and accuracy of the disclosure are urged to be certain
that
they have included all information required pursuant to the
Securities Exchange Act of 1934.

In our comments, we ask you to provide us with supplemental
information so we may better understand your disclosure.  Please
be
as detailed as necessary in your explanation. After reviewing this
information, we may or may not 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 filings.  We look
forward to working with you in these respects.
We welcome any questions you may have about our comments or on any
other aspect of our review.  Feel free to call us at the telephone
numbers listed at the end of this letter.

Form 10-K

Item 9A. Controls and Procedures, page 52
1. We note your disclosures on page 26 where you indicate that the
Company became aware of an incident of possible noncompliance with
the Foreign Corrupt Practices Act and/or with the Company`s
internal
controls in connection with certain of your operations in the
Middle
East.  Supplementally explain how you considered these potential
internal control violations when assessing the Company`s internal
controls over financial reporting.



Note 1 Summary of Significant Accounting Policies

Revenue Recognition, page F-11
2. We note that your accounting policy relating to revenue
arrangements with multiple elements indicates that "If the amount
of
non-contingent revenues allocated to a delivered element is less
than
the costs to deliver such services, then such costs are deferred
and
recognized in future periods when the revenue becomes non-
contingent." Explain to us the facts and circumstances, and cite
the
accounting literature, that you considered in this accounting
policy.

Note 2 - Restructuring and Organization Costs (Benefits), page F-
19
3. We note that during fiscal 2004 and 2003, the Company recorded
a
net benefit of $78,365 and $19,346, respectively, primarily
resulting
from final determinations of certain reorganization liabilities
established in connection with the Company`s transition to a
corporate structure in 2001.  Supplementally explain what these
adjustments were for and what liabilities they related to.  Also,
supplementally provide a breakdown of the $454,042 liability
balance
at August 31, 2004, which relates to the 2001 restructuring and
rebranding costs and tell us when you believe this liability will
be
diminished.

Please respond to these comments within 10 business days or tell
us
when you will provide us with a response.  Please file your letter
on
EDGAR.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filing reviewed by the staff 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.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* 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.



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 our review of your filing or in response to
our comments on your filing.

Please file your response on EDGAR. If you have any questions, you
may contact
Jorge L. Bonilla at (202) 942-1993 or me at (202) 942-2814.


Sincerely,



Kathleen A. Collins

Branch Chief
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Accenture SCA
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