[Letterhead of Sybase, Inc.]

May 16, 2007

Kathleen Collins
Accounting Branch Chief
Securities and Exchange Commission
One Station Place
100 F Street, NE
Washington, D.C. 20549-4561

           Re: Sybase, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2006
Filed on March 1, 2007
Form 8-K dated April 26, 2007
File No. 001-16493

Dear Ms. Collins:

Per our telephone conversation today, we are requesting an extension through June 6, 2007 for our response to the comments set forth in your letter of May 14, 2007 to Sybase’s President and Chief Executive Officer, John Chen. We are seeking such an extension since our Chief Accounting Officer is on vacation starting tomorrow for a week, and we would like to have adequate time to put together a full response upon his return from vacation.

Sincerely,

/s/ Daniel R. Carl

Daniel R. Carl
General Counsel

Cc: Jeff Ross, Dan Cohen