United States securities and exchange commission logo

                              November 28, 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,
                                                            File No. 000-20853

       Dear Nicole Anasenes:

              We have reviewed your November 18, 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 to these comments, we may have
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       November 7, 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
       Other Key Business Metric, page 32

   1.                                                   We note your response
to prior comment 1. Please provide us with the revised disclosures
                                                        that you intend to
include in future filings to describe this metric. Also, ensure that such
                                                        disclosures do not
imply that this measure is intended to replace your GAAP revenue. In
                                                        this regard, your
current disclosure suggests that the metric eliminates volatility caused by
                                                        GAAP. Refer to SEC
Release No. 33-10751.
 Nicole Anasenes
FirstName LastNameNicole Anasenes
Comapany 28,
November  NameANSYS
              2022      INC
Page 2    28, 2022 Page 2
FirstName LastName
2.       We note from your response to prior comment 2 that management is
"required to monitor
         renewal rates on a qualitative directional basis," however, you do not
view renewal rate as
         a key performance metric. Considering a significant portion of your
business relies on
         renewals of your lease licenses and maintenance agreements, please
tell us what
         quantitative measures, if any, you do use to monitor customer
retention and revise to
         include a discussion of such measures.
Results of Operations
Year Ended December 31, 2021 Compared to Year Ended December 31, 2020, page 35

3.       You state in your response to prior comment 3 that you believe you
         quantification of the factors that impacted your revenue growth to the
extent material to an
         investors understanding of your results. Please explain what
quantification you are
         referring to as your current disclosures do not appear to quantify any
of the factors that
         you identify as impacting your revenue growth. Also, provide us with
an example of how
         you intend to revise your disclosures in future filings to address our
comment using the
         current disclosures in your December 31, 2021 Form 10-K.
       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.


                                                               Division of
Corporation Finance
                                                               Office of
cc:      Brad Brasser, Esq.