SecProbe.io

July 24, 2012

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

Re: Tyler Technologies, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2011
Filed February 23, 2012
Form 10 -Q for the Quarterly Period Ended March 31, 2012
Filed April 26, 2012
File No. 001 -10485

Dear Mr. Marr :

We have reviewed your filing s 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 advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances o r do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comment s, we may have  additional comments.

Form 10 -K for t he Fiscal Year Ended December 31, 2011

Note 1 – Summary of Significant Accounting Policies

Revenue Recognition

Subscription -Based Services, page F -9

1. We note your disclosure on page 6 that you provide professional services including
installation and dat a conversion services.  We further note if you determine that you do
not have stand -alone value for professional services associated with ASP and hosting

Mr. John S. Marr
Tyler  Technologies, Inc.
July 24, 2012
Page 2

 arrangements, you recognize the services revenue ratably over the remaining contractual
period.  Pleas e tell us your  basis for recognizing these upfront  fees over the contractual
period  rather than over the estimated customer life based on the guidance in footnote 39
of SAB Topic 13A.3.f.

2. Additionally, please describe your accounting policy  when you concl ude that you do
have stand -alone value for professional services associated with ASP and hosting
arrangements, including how you determined that stand -alone value exists.

3. Finally, we note that you allocate revenue to each qualifying separate element base d upon
vendor -specific objective evidence (VSOE), third party evidence (TPE) or estimated
selling price (ESP).  Please tell us which method is used for your various applicable
products and services and describe how you calculate VSOE, TPE and ESP.

Note 10 – Share -Based Compensation

Determining Fair Value of Stock Compensation, page F -21

4. We note that the simplified method is used to estimate the expected term of your stock
options.  Considering the extent of your exercise activity, please clarify why you continue
to believe that it is appropriate to use the simplified method rather than using historical
information.  Refer to Question 6 of SAB Topic 14.D.2.

Form 10 -Q for the Quarterly Period Ended March 31, 2012

Condensed Statements of Comprehensive Income, page 2

5. We note that historically comprehensive income has differed from net income due to
unrealized gains and losses on investment securities.  Please explain  why comprehensive
income for the three months ended March 31, 2012 and 2011 was equal t o net income
during those periods.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchan ge Act rules require.   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 p rovide  a written statement from the company
acknowledging that:

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

Mr. John S. Marr
Tyler  Technologies, Inc.
July 24, 2012
Page 3

  staff comments or changes to disclosure in response to staff comments do not foreclose
the Commissio n 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 federal securities laws of the United States.

You may contact Jaime John  at (202) 551 -3446 if you have questions regarding
comments on the financial statements and re lated matters.  Please contact me at (202) 551 -3406
with any other questions.

Sincerely,

 /s/ Patrick Gilmore

Patrick Gilmore
Accounting Branch Chief