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,
                                                            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
       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
                                                            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
 Nicole Anasenes
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
         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
       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
FirstName LastName