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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,
2022
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
additional
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
Overview
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
ANSYS INC
Comapany 28,
November NameANSYS
2022 INC
November
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
included
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.
Sincerely,
Division of
Corporation Finance
Office of
Technology
cc: Brad Brasser, Esq.