SecProbe.io

May 20, 2011
 Marc E. Chardon Chief Executive Officer Blackbaud, Inc. 2000 Daniel Island Drive Charleston, South Carolina 29492
Re: Blackbaud, Inc.
 Form 10-K
Filed March 1, 2011 File No. 000-50600

Dear Mr. Chardon:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the fiscal year ended December 31, 2010

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

  Off-Balance Sheet Arrangements, page 51

  1. We note your disclosure in this section that you do not believe
 that you currently have
any off-balance sheet arrangements.  Pl ease tell us why you have qualified your
conclusion and cannot definitively state that you have no off-balance sheet arrangements
as defined in Item 303(a) (4) of Regulation S-K.

 Marc E. Chardon Blackbaud, Inc. May 20, 2011 Page 2
 Compensation Discussion and Analysis (incorpora ted from the definitive proxy statement filed
on April 29, 2011)
  Performance-Based Annual Bonus, page 24

  2. We note that the 2010 bonuses awarded to Messrs. Cumbaa and Mooney were based, in
part, on the performance of thei r respective business units.  In your response letter, tell us
how the performance of these business units was evaluated.  For example, tell us whether you established quantitative or qualitative perf ormance targets for these units and, if you
did, please disclose such targets in your res ponse or provide us with  your analysis as to
why disclosure is not required.  Refer to Item 402(b)(2)(v) of Re gulation S-K.  If you
have omitted performance targets in relian ce upon Instruction 4 to Item 402(b) of
Regulation S-K, please confirm that you will di scuss in future filings how difficult it
would be for the business unit to achieve th e undisclosed targets.  Refer to Question
118.04 of our Regulation S-K Compliance and Di sclosure Interpretations, available on
our website.
  Employment Agreements

Messrs. Williams, Attanasi, Cumbaa and Mooney, page 38
  3. It does not appear that you ha ve filed (or if previously f iled, incorporated by reference
into your Form 10-K) your at-will employ ment agreements with Messrs. Williams,
Attanasi, Cumbaa and Mooney.  Please advise .  Refer to Item 601(b)(10)(iii)(A) of
Regulation S-K.
  Proxy Card

 4. As previously discussed with your counsel, the description of Pr oposal 2 in your proxy
card does not appear to accurately descri be the proposal on which shareholders are
voting.  The resolution on page 12 of the pr oxy statement indicates that stockholders are
voting to approve, on an advisory basis, the compensation of your named executive
officers. The resolution language appears to comply with the requirements of Rule 14a-
21(a).   The Proxy Card, however, indicates  that shareholders  are voting "to hold
 an
advisory vote on executive compensation.”  Pl ease advise on how you intend to resolve
this ambiguity in your proxy card prior to your June 22, 2011 annual meeting.
 Consolidated Financial Statements

 Revenue Recognition, page F-7

 5. We note from your disclosures that any rela ted set-up fees associated with your hosted
subscription arrangements are recognized rata bly over the service period of the contract.

 Marc E. Chardon Blackbaud, Inc. May 20, 2011 Page 3
 Please tell us the life of the subscrip tion period over which you recognize the
implementation fees and explain how you consid er customer renewals in determining the
life of a subscription period. As  part of your response, te ll us how you considered the
guidance in footnote 39 of  SAB Topic 13.A.3(f).
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

• 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 federa l securities laws of  the United States.

You may contact Morgan Y oungwood, Staff Accountant at (202) 551-3479, if you have
questions regarding comments on th e financial statements and related matters.  If you have any
other questions, please contact Ma tthew Crispino, Staff Attorney  at (202) 551-3456 or Barbara
Jacobs, Assistant Director at ( 202) 551-3730.  If you require further assistance, do not hesitate to
contact me at (202) 551-3730.
Sincerely,
   /s/ Craig Wilson
Craig Wilson Senior Assistant Chief Accountant