SecProbe.io

June 17, 2011
 Via email

Brian K. Miller Executive 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 Year Ended December 31, 2010
Filed February 24, 2011 File No. 001-10485

Dear Mr. Miller:
 We have reviewed your filing and have the following comments.  Please note that we
have limited our review to only your financial statements and related disclosures.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Fiscal Year Ended December 31, 2010

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

Financial Condition and Liquidity, page 36
 1. We note that you “currently believe that cash provided by operating activities, cash on
hand and available credit are sufficient to fund [y]our working capital requirements,
capital expenditures, income tax obligations , and share repurchases for the foreseeable
future.”  In future filings, please clarify the time period that constitutes “foreseeable
future.”   Please refer to Instruction 5 to  Item 303(A) of Regulation S-K which indicates

 Brian K. Miller Tyler Technologies, Inc. June 17, 2011 Page 2
 that liquidity should be disc ussed on both a short-term and long-term basis, and FRR
501.03.a which defines short-term as up to 12 mo nths in the future.  This comment also
applies to Form10-Q for the quarterly period ended March 31, 2011.
2. We note that your table of contractual oblig ations on page 39 does not include long-term
debt obligations or related interest.  Pleas e tell us how you considered including these
obligations in your table to comply with th e guidance in Item 303(A )(5)(i) of Regulation
S-K as well as Section II.C of SEC Interp retive Release 33-9144 which indicates that
aggregated information about contractual obligations, contingent liabilities and
commitments should be provided in a single lo cation to improve the transparency of a
company’s liquidity.

Exhibits 31.1 and 31.2

 3. The certifications may not be changed in any respect from the language of
Item 601(b)(31) of Regulation S-K, even  if the change would appear to be
inconsequential in nature.  For guidance, refer to S ection II.B.4 of SEC Release
No. 33-8124.  We note that the identification of  the certifying individual at the beginning
of each of the certifications required by Exchange Act Rule 13a-14(a) filed with your
annual report on Form 10-K and your quarter ly report on Form 10-Q for the quarter
ended March 31, 2011 also include the title of the certifying individual.   In addition, we
note that in the certifications filed with your  annual report on Form 10-K, you refer to
“Tyler” instead of “the registrant.”  Pleas e revise future filings to omit the certifying
individual’s title at the be ginning of the certification and to otherwise conform to the
exact language required by Item 601( b)(31) of Regulation S-K.
  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure 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 comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

 Brian K. Miller Tyler Technologies, Inc. June 17, 2011 Page 3

You may contact David Edgar, Staff Accountant, at (202) 551-3459 if you have questions
regarding comments on the financial statements and related matters.  Please contact me at (202)
551-3406 with any other questions.
Sincerely,
   /s/ Patrick Gilmore
Patrick Gilmore Accounting Branch Chief