SecProbe.io

Room 4561
      April 26, 2007

Mr. John S. Marr
Chief Executive Officer and
President
Tyler Technologies, Inc.
5949 Sherry Lane, Suite 1400
Dallas, TX 75225

Re: Tyler Technologies, Inc.
 Form 10-K for the Fiscal Ye ar Ended December 31, 2006
 Filed March 1, 2007
File No. 001-10485

Dear Mr. Marr:

We have reviewed the above referenced filing and have the following comments.
Please note that we have limited our review  to the matters addr essed in the comments
below.  We may ask you to provide us with  supplemental information so we may better
understand your disclosure.  Please be as detail ed as necessary in your explanation.  After
reviewing this information, we may raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2006

Item 7. Management’s Discussion and Analys is of Financial Condition and Results of
Operations

Overview, page 20

1. We note your disclosure regarding several key performance indicators which you analyze in order to manage your business and evaluate your financial and operating performance.  Information regard ing several of these indicators does not

Mr. John S. Marr
Tyler Technologies, Inc.
April 26, 2007 Page 2
appear to be included within your disclo sures.  These include the number and size
of software license sales, customer ba se and churn, and various categories of
personnel expenses and the related headc ount.  Please tell us what consideration
you gave to providing quantitative disclo sure of these key indicators in your
MD&A.  See Section III.B.1 of SEC Re lease No. 33-8350 that indicates such
disclosure may be required.

Analysis of Results of Operations and Other, page 23

2. In the discussion of your results of opera tions, you refer to various factors that
have impacted results without quantif ying the impact of each factor.  For
example, you refer to several factors that contributed to the increases in software
licenses and services, but give no indication of the relative impact of each factor.
Please explain to us how you considered  Section III.D of SEC Release No. 33-
6835.

Financial Condition and Liquidity, page 29

3. You disclose that cash generated from ope rating activities is your primary source
of liquidity, yet your discussion of opera ting cash flow is limited to a discussion
of your year-end cash balances, days sa les outstanding, and one brief sentence
that refers to “additional maintenance customers and new contract signings.”
When preparing the discussion and analysis of operating cash flows, you should address material changes in the underlying drivers that affect these cash flows.
These disclosures should al so include a discussion of  the underlying reasons for
changes in working capital items that affect  the reconciliation from net income to
operating cash flows.  Please tell us how you concluded that your disclosures provide a sufficient basis for readers to  analyze the changes in your operating
cash flows and how you considered the guidance in Section IV.B.1 of SEC Release 33-8350.

Financial Statements

Note 1.  Summary of Significant Accounting Policies, page F-7

Segment and Related Information, page F-11

4. We note the disclosure on page 4 indi cating that you have four major “product
areas.”  Separately, we not e that your MD&A disclosu res include references to
how certain product areas impacted revenues.  In view of these disclosures, please tell us what consideration you have give n to quantifying revenue for these product
areas in accordance with  paragraph 37 of SFAS 131.

Mr. John S. Marr
Tyler Technologies, Inc.
April 26, 2007 Page 3
 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  Please submit all
correspondence and supplemental materials on EDGAR as required by Rule 101 of Regulation S-T.  You may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cove r letter with any amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing any amendment and your responses to our comments.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing review ed by the staff to be certain that they have provided all
information investors require for an inform ed decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Christine Davis, Sta ff Accountant at (202)  551-3408 or me at
(202) 551-3451 if you have questions regarding these comments.

Sincerely,

Mark Kronforst
       A c c o u n t i n g  B r a n c h  C h i e f