TEXT-EXTRACT 2 filename2.txt September 27, 2018 Stephen M. Kovzan Chief Financial Officer NIC Inc. 25501 West Valley Parkway Suite 300 Olathe, KS 66061 Re: NIC Inc. Form 10-K for the fiscal year ended December 31, 2017 Filed February 22, 2018 Form 10-Q for the quarterly period ended June 30, 2018 Filed August 1, 2018 File No. 000-26621 Dear Mr. Kovzan: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10-Q for the period ended June 30, 2018 Notes to Unaudited Consolidated Financial Statements Note 2. Summary of Significant Accounting Policies Revenue Recognition, page 8 1. Please tell us whether you have any contract costs which you are accounting for under ASC 340-40, and revise your disclosures to include your related policy to the extent such costs are material. In this regard, we note you indicate on page 7 that you are typically responsible for funding the up-front investments and costs of the government portals. Please tell us what these up-front investment costs are, how they are accounted for, and Stephen M. Kovzan NIC Inc. September 27, 2018 Page 2 the amount incurred in each period presented. In closing, 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 Brittany Ebbertt, Senior Staff Accountant, at 202-551-3572 or Craig Wilson, Senior Assistant Chief Accountant, at 202-551-3226 with any questions. Sincerely, FirstName LastNameStephen M. Kovzan Division of Corporation Finance Comapany NameNIC Inc. Office of Information Technologies September 27, 2018 Page 2 and Services FirstName LastName