June 26, 2007

Via U.S. Mail and Facsimile (011-49-622-7783-5403)

Dr. Werner Brandt
Chief Financial Officer
SAP AG
Dietmer-Hopp-Allee 16
69190 Walldorf
Federal Republic of Germany

	Re:	SAP AG
		Form 20-F for the Fiscal Year Ended December 31, 2006
		Filed April 3, 2007
		File No. 1-14251

Dear Dr. Brandt:

      We have limited our review of your Form 20-F for the fiscal
year ended December 31, 2006 to disclosure relating to your
contacts
with countries that have been identified as state sponsors of
terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the
Assistant Director group with respect to other issues.  At this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. 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
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.

General
1. We note the disclosure on pages 11, 32, and 37 of your Form 20-
F
regarding your operations in the Middle East.  We also note
various
news reports that you have set up a training center in Cuba and
that
SAP Arabia distributes your products in Iran, Sudan, and Syria.
Cuba, Iran, Sudan, and Syria are identified as state sponsors of
terrorism by the U.S. Department of State, and are subject to U.S.
economic sanctions and export controls.  Please describe for us
the
nature and extent of your past, current, and anticipated
operations
in, or other contacts with, those countries, whether through
subsidiaries, distributors, or other direct or indirect
arrangements.
Your response should describe in reasonable detail the products
and
services you have provided into the referenced countries, and any
agreements, commercial arrangements or other contacts with the
governments of those countries or entities controlled by them.
2. Please discuss the materiality of the operations and other
contacts described in response to the foregoing comment, and
whether
they would constitute a material investment risk for your security
holders. You should address materiality in quantitative terms,
including the approximate dollar amounts of any associated
revenues,
assets, and liabilities for the period covered by the annual
report
concerning each referenced country.  Also, address materiality in
terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the
potential
impact of corporate activities upon a company`s reputation and
share
value.

We note, for example, that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Missouri Investment Trust has established an
equity
fund for the investment of certain state-held monies that screens
out
stocks of companies that do business with U.S.-designated state
sponsors of terrorism.  The Pennsylvania legislature has adopted a
resolution directing its Legislative Budget and Finance Committee
to
report annually to the General Assembly regarding state funds
invested in companies that have ties to terrorist-sponsoring
countries.  Florida requires issuers to disclose in their
prospectuses any business contacts with Cuba or persons located in
Cuba.  States including California, Connecticut, Maine, New
Jersey,
and Oregon have adopted, and other states are considering,
legislation prohibiting the investment of certain state assets in,
and/or requiring the divestment of certain state assets from,
companies that do business with Sudan.  Harvard University,
Stanford
University, the University of California, and other academic
institutions have adopted policies prohibiting investment in,
and/or
requiring divestment from, companies that do business with Sudan.
Your materiality analysis should address the potential impact of
the
investor sentiment evidenced by such actions directed toward
companies that have operations or business contacts associated
with
Cuba, Iran, Sudan, and Syria.

Your qualitative materiality analysis also should address whether,
and the extent to which, the governments of the referenced
countries,
or persons or entities controlled by those governments, receive
cash
or act as intermediaries in connection with your operations and
contacts.

* * * * *

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

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 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 the
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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comments.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review.  You may also contact me at (202) 551-
3470.

								Sincerely,



								Cecilia Blye, Chief
								Office of Global Security
Risk

cc: 	Barbara Jacobs
		Assistant Director
	Division of Corporation Finance


Dr. Werner Brandt
SAP AG
June 26, 2007
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