July 5, 2006 Mail Stop 4561 By U.S. Mail and facsimile to (650) 213-2956 Mr. Douglas G. Scrivner, General Counsel and Secretary Accenture Ltd Canon`s Court 22 Victoria Street Hamilton HM 12 Bermuda Re:	Accenture SCA 	Form 10-K filed November 5, 2004 	File No. 0-49713 Dear Mr. Scrivner: We have completed our review of your Form 10-K and related filings and have no further comments at this time. 								Sincerely, 	 	Jorge L. Bonilla 				Senior Staff Accountant