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                             August 31, 2023

       Brian Miller
       Chief Financial Officer
       Tyler Technologies, Inc.
       5101 Tennyson Parkway
       Plano, TX 75024

                                                        Re: Tyler Technologies,
Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 22,
2023
                                                            File No. 001-10485

       Dear Brian Miller:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       2022 Compared to 2021, page 32

   1.                                                   We note your
presentation of several non-GAAP measures including revenue and gross
                                                        margin excluding
acquisitions, gross margin excluding the impact of amortization of
                                                        acquired software and
income tax provisions and effective tax rate excluding various
                                                        items; however, you
have not provided the disclosures required disclosures by Item
                                                        10(e)(1)(i) of
Regulation S-K nor have you labelled these items as non-GAAP. Please
                                                        revise to provide the
required disclosures or alternatively incorporate the quantitative
                                                        impact of these items
in your discussion of the changes in the respective line items.
       Revenues, page 33

   2.                                                   We note your
presentation of several revenue line items excluding acquisitions. We also
                                                        note the footnotes
indicate that the amounts exclude the "incremental impact as a result of
 Brian Miller
Tyler Technologies, Inc.
August 31, 2023
Page 2
         not having the recent acquisition for a full fiscal year." Please
explain to us how the 2022
         adjustments were calculated and explain why the 2021 revenue amounts
are not
         adjusted considering that there was a significant acquisition in 2021.
In this regard, the
         total subscription revenue excluding acquisitions for 2021 is
presented as $784,435;
         however, based on the preceding table that amount includes $368,917 in
revenue from
         acquisitions in that year.
Annualized Recurring Revenues, page 34

3.       We note this measure is calculated based on quarter-end total
recurring revenue multiplied
         by four and that recurring revenue includes transaction-based revenue.
However, it is not
         clear how you consider transaction-based revenue to be recurring as it
would appear
         amounts could change period to period as a result of volume
fluctuations and seasonality.
         In this regard, you indicated in your earnings call for the six months
ended June 30, 2023
         that transaction revenues are typically the highest in the second
quarter coinciding with
         peak outdoor seasons and tax deadlines and at a seasonal low in the
fourth quarter with
         fewer business days and less activity around the holidays. Please
revise to disclose how
         you account for transaction-based revenue in the measure, noting
estimates and
         assumptions used and the limitations that result, as well as how
volatile amounts may be
         period to period and the impact of seasonality. Further, revise to
disclose whether ARR is
         indicative of future revenue and if not, how it may differ. Also,
revise to disclose why
         ARR is useful to investors and indicate how management uses ARR in
managing or
         monitoring company performance. Refer to Release No. 33-10751.
Consolidated Financial Statements
Note (1) Summary of Significant Accounting Policies
Goodwill, page F-16

4.     You disclose here and on page 30 that you "performed qualitative
assessments for the
       remaining reporting units in which we determined that it [was] not more
likely than not
       that the fair value exceeded the carrying value...". This appears to
suggest that the
       carrying value of these reporting units could exceed the fair value, and
does not appear to
       be consistent with the rest of the sentence, which indicates you did not
perform a Step
       1 quantitative impairment test. We also note that you disclose that you
FirstName LastNameBrian Miller
       performed qualitive assessments for certain recently acquired reporting
units; however the
Comapany
       auditNameTyler    Technologies,
             report indicates           Inc. assessments were performed. Please
revise to
                              that quantitative
Augustaddress
        31, 2023these
                  Pageinconsistencies.
                        2
FirstName LastName
 Brian Miller
FirstName  LastNameBrian
Tyler Technologies, Inc. Miller
Comapany
August 31, NameTyler
           2023        Technologies, Inc.
August
Page 3 31, 2023 Page 3
FirstName LastName
       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 Melissa Kindelan, Senior Staff Accountant, at (202)
551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology