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[Progress Software Letterhead]

May 14, 2007

VIA EDGAR

Mr. Mark Kronforst

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:

    Progress Software Corporation

Form 10-K for Fiscal Year Ended November 30, 2006

Filed February 13, 2007

Form 8-K Filed March 20, 2007

File No. 000-19417

Dear Mr. Kronforst:

This letter is submitted on behalf of Progress Software Corporation (“we” or the “Company”) in
response to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the
Securities and Exchange Commission (the “Commission”) raised in your letter of April 30, 2007 to
Joseph W. Alsop, Chief Executive Officer of the Company (the “Comment Letter”). For reference
purposes, the text of the Comment Letter has been reproduced herein with responses below each
numbered comment.

Form 10-K for the Year Ended November 30, 2006

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Fiscal 2005 Compared to Fiscal 2004, page 20

    1.

    Your response to prior comment number 1 indicated that you believe that volume is a key
indicator. You further indicated that your disclosures are consistent with the spirit of the
disclosure requirements of Section III.B.1 of SEC Release No. 33-8350. Tell us why you do not
believe that further quantitative disclosure regarding volume is required in order to comply
with the release. Note that the release indicates that disclosure of key indicators that are
used by management and would be material to investors is required.

Response 1:

We believe that we comply with the spirit of the disclosure requirements as the points that we
discuss in MD&A are the same measures that we utilize internally. Our key internal indicators are
the amount of revenue for a particular product line, such as OpenEdge, DataDirect, etc. and the
impact of changes in such revenue due to foreign exchange rate movement. We do not actively
monitor the number of licenses or number of users, but referenced volume in our filings to
delineate from price changes. As previously noted, we have not experienced significant changes in
prices.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 1: Nature of Business and Summary of Significant Accounting Policies

Revenue Recognition, page 33

    2.

    We have read your response to prior comment number 3 and recognize that your use of contract
accounting is minimal. However, you should note that the accounting requirements of the
proportional performance method are not the equivalent of the percentage-of-completion as you
indicated in your response. Although the application of the proportional performance model to
service transactions frequently results in revenue recognition based on the percentage of
completion of the service, it is not appropriate to recognize costs in the same manner.
Please ensure that your accounting for these contracts reflects this distinction.

Response 2:

We will ensure that our accounting for service arrangements reflects this distinction. In
addition, while such service arrangements have historically been insignificant, we have reviewed
such arrangements and our historical accounting also reflects this distinction.

Form 8-K filed March 20, 2007

Exhibit 99.1

    3.

    We believe that the columnar format of the “Non-GAAP Condensed Consolidated Statements of
Income” appearing in your earnings release furnished in the Form 8-K may create the
unwarranted impression to investors that this non-GAAP statement of income has been prepared
under a comprehensive set of accounting rules and principles while also conveying undue
prominence to a statement based on non-GAAP measures. In addition, Section II.A.2 of SEC
Release 33-8176 defines non-GAAP measures and does not contemplate including non-GAAP
financial statements as a “measure.” Please remove that presentation, or explain to us in
reasonable detail why its retention is justified in light of these concerns.

    As a substitute for this presentation format, you may consider presenting only individual
non-GAAP measures (i.e. line items, subtotals, etc.) provided each one complies with Item
10 of Regulation S-K and the Division of Corporation Finance’s Frequently Asked Questions
Regarding Use of Non-GAAP Financials, Question 8.

Response 3.

In future Form 8-K filings that furnish press releases with financial information that contain
non-GAAP financial measures, we will not include “Non-GAAP Condensed Consolidated Statements of
Income,” but will instead present the individual non-GAAP financial measures as either subtotals or
line items with a reconciliation to the directly comparable GAAP measure and otherwise in
compliance with Item 10(e)(1)(i) of Regulation S-K and the Division of Corporation Finance’s
Frequently Asked Questions Regarding Use of Non-GAAP Financials, Question 8.

If you should have any questions concerning the enclosed matters, please contact the undersigned at
781-280-4524.

Sincerely,

/s/ David H. Benton, Jr.

David H. Benton, Jr.

Vice President and Corporate Controller

    cc:

    David Edgar

Norman R. Robertson, Senior Vice President and Chief Financial Officer

Joseph W. Alsop, Chief Executive Officer