SecProbe.io

Room 4561
      May 23, 2007

Mr. Brian K. Miller
Senior Vice President and
Chief Financial Officer
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. Miller:

We have reviewed your response letter dated May 9, 2007 and have the following
additional comment.  We may ask you to pr ovide us with supplemental information so
we may better understand your disclosure.  Pl ease be as detailed as necessary in your
explanation.  After reviewing this info rmation, 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

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

Segment and Related Information, page F-11

1. We note your response to prior comment number 4 and we do not believe that you have adequately supported your conclu sion that the products are similar and
additional disclosure is not required pu rsuant to paragraph 37 of SFAS 131.  For
example, it is unclear how a software product used by law enforcement agencies for jail management is similar to one that is used by industry professionals in

Mr. Brian K. Miller
Tyler Technologies, Inc.
May 23, 2007 Page 2
property appraisal.  Despite the common characteristic of your customers being
associated with local governments, it appears that your analysis regarding
similarity may be overly broad.  Provide us  with a more detaile d analysis of why
you believe the following categories of your solutions are similar in the context of
paragraph 37:

• Finance & Accounting;
• Courts & Justice;
• Public Safety;
• Appraisal & Tax;
• Education Management;
• Forms, Documents & Content Management; and
• Land & Vital Records.

 Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  submit all correspondence and supplemental
materials on EDGAR as required by Rule 101 of Regulation S-T.  If you amend your
filing(s), you may wish to provide us with marked copies of any amendment to expedite our review.  Please furnish a cover letter that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing any
amendment and your responses to our comments.

 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