Mail Stop 4561
                                                           August 28, 2018


Maria T. Shields
Chief Financial Officer
ANSYS Inc.
2600 ANSYS Drive
Canonsburg, PA 15317

       Re:    ANSYS Inc.
              Form 10-K for the Fiscal Year Ended December 31, 2017
              Filed February 22, 2018
              Form 10-Q for the Quarterly Period Ended March 31, 2018
              Filed May 3, 2018
              File No. 000-20853

Dear Ms. Shields:

       We have limited our review of your filings 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-Q for the Quarterly Period Ended March 31, 2018

Notes to Condensed Consolidated Financial Statements

Note 3. Revenue from Contracts with Customers, page 9

1.     You disclose that you apply a practical expedient to expense sales
commissions as
       incurred when the amortization period would have been one year or less.
Please tell us
       whether sales commissions are earned on contract renewals and if so, how
you
       considered those in determining the amortization period.

2.     You disclose that certain sales commissions associated with multi-year
contracts are
       subject to an employee service requirement and are expensed as incurred
as they are not
 Maria T. Shields
ANSYS Inc.
August 28, 2018
Page 2

       considered incremental costs to obtain a contract. Please tell us the
nature of the service
       requirement and how it impacted your consideration in accounting for
these sales
       commissions. Also, tell us whether sales commissions are earned on
multi-year contracts
       that are not subject to an employee service requirement and, if so, how
you account for
       such commissions.

       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 David Edgar, Staff Accountant, at (202) 551-3459 or
Melissa Kindelan,
Staff Accountant, at (202) 551-3564 if you have questions regarding comments on
the financial
statements and related matters. Please contact me at (202) 551-3226 with any
other questions.

                                                            Sincerely,

                                                            /s/ Craig D. Wilson

                                                            Craig D. Wilson
                                                            Senior Assistant
Chief Accountant
                                                            Office of
Information Technologies
                                                            and Services