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August 31, 2023
Brian Miller
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, 2022
Filed February 22, 2023
File No. 001-10485
Dear Brian 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-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
2022 Compared to 2021, page 32
1.We note your presentation of several non-GAAP measures including revenue and gross
margin excluding acquisitions, gross margin excluding the impact of amortization of
acquired software and income tax provisions and effective tax rate excluding various
items; however, you have not provided the disclosures required disclosures by Item
10(e)(1)(i) of Regulation S-K nor have you labelled these items as non-GAAP.  Please
revise to provide the required disclosures or alternatively incorporate the quantitative
impact of these items in your discussion of the changes in the respective line items.
Revenues, page 33
2.We note your presentation of several revenue line items excluding acquisitions.  We also
note the footnotes indicate that the amounts exclude the "incremental impact as a result of

 FirstName LastNameBrian Miller
 Comapany NameTyler Technologies, Inc.
 August 31, 2023 Page 2
 FirstName LastName
Brian Miller
Tyler Technologies, Inc.
August 31, 2023
Page 2
not having the recent acquisition for a full fiscal year."  Please explain to us how the 2022
adjustments were calculated and explain why the 2021 revenue amounts are not
adjusted considering that there was a significant acquisition in 2021.  In this regard, the
total subscription revenue excluding acquisitions for 2021 is presented as $784,435;
however, based on the preceding table that amount includes $368,917 in revenue from
acquisitions in that year.
Annualized Recurring Revenues, page 34
3.We note this measure is calculated based on quarter-end total recurring revenue multiplied
by four and that recurring revenue includes transaction-based revenue.  However, it is not
clear how you consider transaction-based revenue to be recurring as it would appear
amounts could change period to period as a result of volume fluctuations and seasonality.
In this regard, you indicated in your earnings call for the six months ended June 30, 2023
that transaction revenues are typically the highest in the second quarter coinciding with
peak outdoor seasons and tax deadlines and at a seasonal low in the fourth quarter with
fewer business days and less activity around the holidays.  Please revise to disclose how
you account for transaction-based revenue in the measure, noting estimates and
assumptions used and the limitations that result, as well as how volatile amounts may be
period to period and the impact of seasonality.  Further, revise to disclose whether ARR is
indicative of future revenue and if not, how it may differ.  Also, revise to disclose why
ARR is useful to investors and indicate how management uses ARR in managing or
monitoring company performance.  Refer to Release No. 33-10751.
Consolidated Financial Statements
Note (1) Summary of Significant Accounting Policies
Goodwill, page F-16
4.You disclose here and on page 30 that you "performed qualitative assessments for the
remaining reporting units in which we determined that it [was] not more likely than not
that the fair value exceeded the carrying value...".  This appears to suggest that the
carrying value of these reporting units could exceed the fair value, and does not appear to
be consistent with the rest of the sentence, which indicates you did not perform a Step
1 quantitative impairment test.  We also note that you disclose that you
performed qualitive assessments for certain recently acquired reporting units; however the
audit report indicates that quantitative assessments were performed.  Please revise to
address these inconsistencies.

 FirstName LastNameBrian Miller
 Comapany NameTyler Technologies, Inc.
 August 31, 2023 Page 3
 FirstName LastName
Brian Miller
Tyler Technologies, Inc.
August 31, 2023
Page 3
            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 Melissa Kindelan, Senior Staff Accountant, at (202) 551-3564 or
Christine Dietz, Senior Staff Accountant, at (202) 551-3408 with any questions.
Sincerely,
Division of Corporation Finance
Office of Technology