SecProbe.io

September 17, 2018
Brian K. Miller
Executive Vice President and Chief Financial Officer
Tyler Technologies, Inc.
5101 Tennyson Parkway
Plano, TX 75024
Re:Tyler Technologies, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2017
Filed February 21, 2018
Form 10-Q for the Quarterly Period Ended June 30, 2018
Filed August 1, 2018
File No. 001-10485
Dear Mr. Miller:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Quarterly Period Ended June 30, 2018
Note 2. Accounting Standards and Significant Accounting Policies
Revenue Recognition
Software Licenses and Royalties, page 6
1.Your disclosures appear to indicate that royalty revenue is not recognized until you
receive notice of amounts earned which is in the quarter subsequent to the quarter the
royalty is actually earned.  Please tell us how this complies with ASC 606-10-55-65.
However, we also note that the disclosure on page 7 of your Form 10-Q for the quarterly
period ended March 31, 2018 indicates that royalties are recognized on an estimated basis
in the period earned and are then trued up when you receive notice of amounts earned.

 FirstName LastNameBrian K. Miller
 Comapany NameTyler Technologies, Inc.
 September 17, 2018 Page 2
 FirstName LastName
Brian K. Miller
Tyler Technologies, Inc.
September 17, 2018
Page 2
Please reconcile these disclosures and tell us whether there has been a change in
accounting for royalties.
Subscription-Based Services , page 7
2.You disclose that software and software services that are contingent on the transfer
of other performance obligations are recognized ratably.  Please tell us what these
contingent performance obligations are and how they impact your revenue recognition.
Refer to the authoritative guidance you relied upon.
Deferred Commissions, page 10
3.Please tell us, and revise to clarify, whether sales commissions paid upon contract renewal
are commensurate with the initial commissions and disclose how commissions paid for
renewals are considered in the three to seven year period of benefit for the initial
commission.  You also disclose that renewals are amortized over the “remaining period of
benefit.”  Please tell us whether the period of benefit for these commissions exceeds the
term of the respective customer contract and if so, explain what the remaining period of
benefit represents and how your policy complies with ASC 340-40-35-1.  Also refer to
ASC 340-40-50-2(b).
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Frank Knapp, Staff Accountant at (202) 551- 3805 or  Christine Dietz,
Assistant Chief Accountant at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services