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February 9, 2006

Mr. Stathis Kouninis

Staff Accountant

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, DC 20549

VIA FAX AND EDGAR

Dear Mr. Kouninis:

Attached is supplemental information provided to clarify our response dated December 14, 2005 to
comment number 4 in the Staff’s comment letter dated November 17, 2005. This information is
intended to provide additional detail on how the Company determined the weighted average life for
acquired customer bases.

Additionally, the Company acknowledges that:

    •

    The Company is responsible for the adequacy and accuracy of the disclosure in its filings;

    •

    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 federal securities laws of the United States.

If you have further questions or require additional information, please contact me at (972)
713-3720. My fax number is (972) 713-3741.

Sincerely,

Brian K. Miller

Senior Vice President and

Chief Financial Officer

Tyler Technologies, Inc.

Supplemental Response

Comment No. 4 — Customer Life

Table 1

Calculation of Customer Lives

    Customer

    Annual

    Life

    Attrition

    Calculated

    Used for

    Rate per

    Customer

    Amortization

    Appraisal

    Life (years)

    (years)

    Report

    (Note A)

    (Note B)

    Division 1

    3
    %

    33

    20

    Division 2

    3
    %

    33

    20

    Division 3

    4
    %

    25

    25

    Division 4 (Note C)

    1
    %

    100

    20

    Division 5

    4
    %

    25

    25

    Division 6

    3
    %

    33

    20

Table 2

Calculation of Weighted Average Customer Life

    Customer

    Value

    Percentage

    Life per

    Weighted

    Assigned to

    of Total

    Table 1

    Life

    Customer

    Customer

    Above

    (years)

    Base

    Base Value

    (years)

    (Note D)

    Division 1

    $
    8,912

    37
    %

    20

    7

    Division 2

    $
    1,527

    6
    %

    20

    1

    Division 3

    $
    6,280

    26
    %

    25

    6

    Division 4

    $
    2,300

    9
    %

    20

    2

    Division 5

    $
    2,700

    11
    %

    25

    3

    Division 6

    $
    2,560

    11
    %

    20

    2

    $
    24,279

    100
    %

    22

    Note (A)

    The calculated customer life is the inverse of the annual customer attrition rate.
For example, if the customer attrition rate is 3% annually, then it would take
33 years to lose the entire customer base. If the attrition rate is 4%, it would
take 25 years to lose 100% of the customers.

    Note (B)

    Although the calculated customer lives based on historical customer
attrition rates were greater, we capped the life used for amortization at
the period over which we were amortizing goodwill.

    Note (C)

    The table on page 6 of our response letter dated December 14, 2005
contained a typographical error. The attrition rate for Division 4 per
the appraisal report was actually 1%, rather than the 8% rate shown
in the table in our previous response.

    Note (D)

    The weighted life is calculated by multiplying the percentage of total customer
base value times the customer life. The sum of the weighted averages is
22 years.