SEC Comment Letter for TYLER TECHNOLOGIES INC (TYL) (CIK 0000860731) (TYL) — Oct 16, 2012
TYLER TECHNOLOGIES INC (TYL) (CIK 0000860731)
Date: Oct. 16, 2012 · CIK: 0000860731 · Accession: 0000000000-12-057035
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October 16, 2012 Via Facsimile Mr. Brian K. Miller Chief Financial Officer 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 File No. 001 -10485 Dear Mr. Miller : We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or 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 Un ited States. 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 rules require. Sincerely, /s/ Patrick Gilmore Patrick Gilmore Accounting Branch Chief