[Letterhead of Sybase, Inc.]

June 27, 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 exchange, we are requesting an extension through July 13, 2007 for our response to the comments set forth in your letter of June 15, 2007 to Sybase’s President and Chief Executive Officer, John Chen. We are seeking such an extension to allow our finance and accounting staff to have sufficient time to gather the requested information during the typically busy end of quarter period.

Sincerely,

/s/ Daniel R. Carl

Daniel R. Carl
General Counsel

Cc:  Jeff Ross, Dan Cohen