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March 14, 2023
Kristian Talvitie
Chief Financial Officer
PTC Inc.
121 Seaport Boulevard
Boston, MA 02210
Re:PTC Inc.
Form 10-K for the Fiscal Year Ended September 30, 2022
Filed November 15, 2022
File No. 000-18059
Dear Kristian Talvitie:
            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-K for the Fiscal Year Ended September 30, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Operating Measure - ARR, page 30
1.You disclose that annual run rate ("ARR"), defined as “annualized value of our portfolio
of active subscription software, cloud, SaaS, and support contracts as of the end of the
reporting period,” is an operating metric used to measure the health of your subscription
business as it captures expected subscription and support cash generation from customers.
We also note that subscription revenue includes on-premises term-based license revenue,
for which revenue is recognized at a point-in-time.  Please address the following:
•Clarify how this measure is calculated.  Specifically address how the up-front
revenue received from term licenses is factored into your ARR calculation and
provide examples to help explain such calculations.  Clarify whether you annualize
revenue recognized or invoiced amounts.
•Tell us the length of a typical subscription contract term and explain how you

 FirstName LastName Kristian Talvitie
 Comapany NamePTC Inc.
 March 14, 2023 Page 2
 FirstName LastName
 Kristian Talvitie
PTC Inc.
March 14, 2023
Page 2
consider contract renewals in your ARR calculations.
•Explain how multi-year contracts are factored into your calculations and tell us the
amount of revenue recognized from multi-year contracts for each period presented
and the typical terms of such arrangements.
•Explain how any software exchanges, additions to current customer subscriptions,
and new customer subscriptions acquired are factored into your calculation.  Please
provide an example to explain these calculations.
•Clarify whether ARR reflects any actual or anticipated reductions of revenue due to
contract non-renewals or cancellations, and discuss any limitations present as a result.
•Revise to describe how ARR differs from GAAP revenue and specifically address the
timing of revenue recognition related to the license performance obligation.
Additionally, please consider disclosing any of the above information to the extent
material.
•Provide us with proposed disclosure responsive to the concerns noted above.  Refer
to SEC Release 33-10751.
            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 Christine
Dietz, Senior Staff Accountant, at 202-551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology