March 15, 2005

Via U.S. Mail

Mr. Scott G. McNealy
Chief Executive Officer
Sun Microsystems, Inc.
4150 Network Circle
Santa Clara, CA 95054

RE:		Sun Microsystems, Inc.
      Form 10-K for the fiscal year ended June 30, 2004
		File No. 0-15086

Dear Mr. McNealy:

      We have limited our review of your Form 10-K to disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and will make no further review of
the
Form 10-K.  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 or may not 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 -

We note the disclosure in your Form 10-K for the fiscal year ended
Jun 30, 2003, and your Form 10-Q for the fiscal quarter ended
September 28, 2003, regarding communications from the U.S.
Commerce
Department`s Bureau of Industry and Security relating to possible
violations of law in connection with your exports to Syria, and
the
fact that a denial of export privileges by the Bureau as penalty
for
any violations would have a material adverse effect on your
business.
We note also that, while your Form 10-K for the fiscal year ended
June 30, 2004 discusses your settlement arrangements with the
Bureau,
and includes general disclosure about the risks associated with
your
international customers and operations and the adverse
consequences
that would flow from any violation of export control laws, that
filing makes no mention of any activity specifically related to
Syria.

Advise us whether you exported to Syria during 2004, and whether
you
currently export to Syria.  Furthermore, in light of the fact that
Syria has been identified by the U.S. State Department as a state
sponsor of terrorism and is subject to economic sanctions
administered by the U.S. Treasury Department`s Office of Foreign
Assets Control, please describe for us in reasonable detail the
Company`s past, and any present, operations in Syria; advise us of
the materiality to the Company of its operations in Syria; and
give
us your view as to whether those operations constitute a material
investment risk for your security holders.  In preparing your
response, please consider that evaluations of materiality should
not
be based solely on quantitative factors, but should include
consideration of all factors, including the potential impact of
corporate activities upon a company`s reputation and share value,
that a reasonable investor would deem important in making an
investment decision.


Closing

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 942-7896 if you have any questions about the comment or
our
review.  You may also contact me at (202) 942-7817.


								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk


cc: 	Barbara Jacobs
		Assistant Director
		Division of Corporation Finance