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December 18, 2006

Mr. Herbert Scholl

Office of EDGAR and Information Analysis

Securities and Exchange Commission

Washington, D.C. 20549

Ladies and Gentlemen:

On December 14, 2006, our client, Tech Data Corporation (the “Company”), filed an automatic shelf registration statement (File No. 333-139340) with the Securities and Exchange Commission (the “Commission”) that became effective immediately upon filing pursuant to Rule 462(e). Although the proper Form S-3ASR was attached to the EDGAR filing and the correct box was checked on the cover page of the registration statement to identify the filing as an automatically effective filing under Rule 462(e), the submission header incorrectly listed it as a Form S-3 rather than a Form S-3ASR.

Based on discussions with the staff of the Commission, we understand that to correct this error, the Company should file a Form RW to withdraw the incorrectly categorized filing, and then simultaneously file the Form S-3ASR with the proper submission header.

We respectfully request that you withdraw the Form S-3 filed on December 14, 2006, SEC Accession No. 0001193125-06-253374 from the EDGAR system and that the date and time of the Form S-3ASR filing containing the correct submission header be adjusted to match the date and time of the original filing (December 14, 2006; 16:09:03).

Thank you for your assistance in this matter.