June 7, 2019

Kenneth Stillwell
Chief Financial Officer
Pegasystems Inc.
One Rogers Street
Cambridge, MA 02142

       Re: Pegasystems Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 20, 2019
           File No. 001-11859

Dear Mr. Stillwell:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Business Overview, page 21

1.     We note the decline in gross profit resulting from the shift to cloud
arrangements and the
       decrease in income (loss) from operations from fiscal year 2017 to 2018,
which continued
       into the first quarter of 2019. Please tell us how long you believe this
trend will
       continue and revise, as necessary, to include a discussion of any known
trends that have
       had or that you reasonably expect will have an impact on revenue and
income (loss) from
       operations. Refer to Item 303(a)(3)(ii) of Regulation S-K.
 Kenneth Stillwell
Pegasystems Inc.
June 7, 2019
Page 2
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue, page 39

2.    You indicate that your arrangements can include variable fees such as the
option to
      purchase additional usage of a previously delivered software license. You
also note that
      you include an estimate of these variable fees in the total transaction
price based on
      expected purchase volumes. Please further explain the variable fees in
these arrangements
      including how the additional usage is related to the delivered software
license, how such
      fees are accounted for, as well as your consideration of the guidance in
ASC 606-10-55-
      65. Lastly, tell us the amount of revenue recognized from these variable
fees for each
      period presented.
Deferred Contract Costs, page 40

3.    You disclose that deferred costs for maintenance renewals and cloud
arrangements are
      amortized over an average expected benefit period of five years. Please
further explain
      whether commissions are earned for each renewal of a maintenance period,
such as a one-
      year term, for example, and if so how you account for each renewal
commission. With
      regards to your cloud arrangements, tell us whether the commissions you
refer to are for
      the initial contract. Also, tell us whether commissions are earned on
cloud arrangement
      renewals and if so, tell us whether they are commensurate with the
commissions earned on
      the initial contract and how you account for such commissions. Revise and
clarify your
      disclosure accordingly. Refer to ASC 340-40-35-1.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Frank Knapp, Staff Accountant, at (202) 551-3805 or
Melissa Kindelan,
Staff Accountant, at (202) 551-3564 if you have questions regarding comments on
the financial
statements and related matters. Please contact Kathleen Collins, Accounting
Branch Chief at
(202) 551-3499 with any other questions.



                                                          Sincerely,

FirstName LastNameKenneth Stillwell                       Division of
Corporation Finance
                                                          Office of Information
Technologies
Comapany NamePegasystems Inc.
                                                          and Services
June 7, 2019 Page 2
cc:       Efstathios Kouninis
FirstName LastName