SEC Comment Letter 0000000000-22-013438 to ANSYS INC (ANSS) (CIK 0001013462)
ANSYS INC (ANSS) (CIK 0001013462)
Date: Dec. 13, 2022 · CIK: 0001013462 · Accession: 0000000000-22-013438
AI Filing Summary & Sentiment
File numbers found in text: 000-20853
Letter
United States securities and exchange commission logo December 13, 2022 Nicole Anasenes Chief Financial Officer ANSYS Inc. 2600 ANSYS Drive Canonsburg, PA 15317 Re:ANSYS Inc. Form 10-K for the Year Ended December 31, 2021 Filed February 23, 2022 File No. 000-20853 Dear Nicole Anasenes: We have reviewed your December 8, 2022 response to our comment letter 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, we may have additional comments. Unless otherwise noted, our references to prior comments are those in our November 28, 2022 letter. Form 10-K for the Fiscal Year Ended December 31, 2021 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 34 1.We note your proposed revised disclosures in response to prior comment 3. While we acknowledge that you have quantified the percentage change in your various revenue streams, your proposed disclosure does not quantify the underlying factors that contributed to the change in your lease license license, perpetual license, service or maintenance revenues. For example, you state that the increase in lease license revenue was driven by growth in existing multi-year licenses and a shift toward multi-year lease products from annual product sales. Please further revise to quantify the underlying factors that contributed to the change in each revenue stream. Also, refrain from using terms such as "primarily" in lieu of providing more specific quantitative disclosure. Refer to Item 303(b) of Regulation S-K.
FirstName LastNameNicole Anasenes Comapany NameANSYS Inc. December 13, 2022 Page 2 FirstName LastName Nicole Anasenes ANSYS Inc. December 13, 2022 Page 2 You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Brad Brasser, Esq.
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United States securities and exchange commission logo
December 13, 2022
Nicole Anasenes
Chief Financial Officer
ANSYS Inc.
2600 ANSYS Drive
Canonsburg, PA 15317
Re:ANSYS Inc.
Form 10-K for the Year Ended December 31, 2021
Filed February 23, 2022
File No. 000-20853
Dear Nicole Anasenes:
We have reviewed your December 8, 2022 response to our comment letter 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, we may have additional comments. Unless otherwise
noted, our references to prior comments are those in our November 28, 2022 letter.
Form 10-K for the Fiscal Year Ended December 31, 2021
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 34
1.We note your proposed revised disclosures in response to prior comment 3. While we
acknowledge that you have quantified the percentage change in your various revenue
streams, your proposed disclosure does not quantify the underlying factors that
contributed to the change in your lease license license, perpetual license, service or
maintenance revenues. For example, you state that the increase in lease license revenue
was driven by growth in existing multi-year licenses and a shift toward multi-year lease
products from annual product sales. Please further revise to quantify the underlying
factors that contributed to the change in each revenue stream. Also, refrain from using
terms such as "primarily" in lieu of providing more specific quantitative disclosure. Refer
to Item 303(b) of Regulation S-K.
FirstName LastNameNicole Anasenes
Comapany NameANSYS Inc.
December 13, 2022 Page 2
FirstName LastName
Nicole Anasenes
ANSYS Inc.
December 13, 2022
Page 2
You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc: Brad Brasser, Esq.