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United States securities and exchange commission logo
November 7, 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 limited our review of your filing 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-K for the 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. Please explain to us,
and revise your disclosures as necessary to clarify, how you calculate
the annualized value of
lease contracts for your key business metric of annual contract
value (ACV). At a
minimum, address the following:
Clarify whether ACV
is impacted by the timing of revenue recognition (e.g. up-front
recognition for
the term license).
Provide us with an
example of a term license contract with a mid-year start date to
illustrate your
calculations.
Explain how your
calculations may be impacted if the maintenance or lease contract
has a multi-year
term and provide us an example of the ACV during each year of the
contract.
Nicole Anasenes
ANSYS INC
November 7, 2022
Page 2
Tell us the typical terms of your multi-year lease licenses and
the percentage of
revenue from multi-year lease licenses for each period presented.
Explain your reference to "anniversary dates" and to the extent
this relates to the
renewal date of your contracts, tell us why fixed-term service
contracts would renew.
Revise your disclosures to clarify your statement that "summed
over the long-term,
ACV and revenue are equal" and describe further how this measure
differs from
GAAP revenue.
2. We note that you rely on high renewal rates for your annual lease and
maintenance
contracts. Please tell us the renewal rates for each period covered by
your financial
statements, including interim periods, and tell us your consideration
to quantify such rates
in future filings. Alternatively, tell us what measures you use to
monitor customer
retention and revise to include a quantified discussion of measures.
Refer to SEC Release
No. 33-10751.
Results of Operations
Year Ended December 31, 2021 Compared to Year Ended December 31, 2020, page 35
3. You refer to various factors that impacted your revenue growth such as
new license and
maintenance sales, maintenance renewals, and your recent acquisitions.
Where a material
change from period-to-period is due to two or more factors, including
any offsetting
factors, please revise to describe the underlying reasons for the
material changes in both
quantitative and qualitative terms. Refer to Item 303(b) of Regulation
S-K.
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, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.
FirstName LastNameNicole Anasenes Sincerely,
Comapany NameANSYS INC
Division of
Corporation Finance
November 7, 2022 Page 2 Office of
Technology
FirstName LastName