Mail Stop 4-06

								January 9, 2006

W. Michael Kipphut
Senior Vice President and Chief Financial Officer
Sykes Enterprises, Incorporated
400 N. Ashley Drive
Tampa, FL 33602

	Re:	Sykes Enterprises, Incorporated
      Form 10-K for Fiscal Year Ended December 31, 2004
Forms 10-Q for Fiscal Quarters Ended March 31, 2005, June 30, 2005
and September 30, 2005
      File No. 000-28274

Dear Mr. Kipphut:

      We have reviewed your response letter dated December 13,
2005
and have the following comments.  Please note that we have limited
our review to the matters addressed in the comments below.  We may
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 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 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 for Fiscal Year Ended December 31, 2004

Prior Comment no. 1

1. You state in your response that the Company uses the residual
method of accounting under paragraph 12 of EITF 00-21 to determine
the amount of the total contractual fee to allocate to
Infrastructure
Services.  Paragraph 12 of EITF 00-21 indicates that using a
residual
method to determine the fair value of an undelivered item is not
an
acceptable method of allocating arrangement consideration to the
separate units of accounting.  Given that Infrastructure Services
relate to the on-going monitoring and support of  IT and
telecommunications infrastructure (i.e., providing on-going
maintenance, development and testing), it appears to represent an
undelivered element, which would require the Company to amortize
the
entire arrangement fee to revenues over the life of the agreement
given that residual method would not apply.  Revise the filing
accordingly, or tell us why such revision is not required.

Prior Comment no. 2
2. We note your response to our previous comment no. 2 where you
indicate that certain deferred revenues included in current
liabilities represent up-front fees received on multi-year
contracts
that contain cancellation and refund provisions.  In future
filings,
revise your Summary of Significant Accounting Policies footnote to
include a discussion of the components of your deferred revenues
to
specifically discuss the inclusion of multi-year contracts in
current
liabilities.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  Please submit all correspondence and
supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  You
may wish to provide us with marked copies of any amendment to
expedite our review.  Please furnish a cover letter with any
amendment that keys your responses to our comments and provides
any
requested information.  Detailed cover letters greatly facilitate
our
review.  Please understand that we may have additional comments
after
reviewing any amendment and your responses to our comments.

	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 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.

      You may contact Megan Akst, Staff Accountant, at (202) 551-
3407
or me at (202) 551-3499 if you have questions regarding comments
on
the financial statements and related matters.

							Very truly yours,



							Kathleen Collins
      Accounting Branch Chief
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W. Michael Kipphut
Sykes Enterprises, Incorporated
January 9, 2006
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