United States securities and exchange commission logo

                              December 13, 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 December 8, 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, we may have additional comments.
Unless otherwise
       noted, our references to prior comments are those in our November 28,
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
       Results of Operations, page 34

   1.                                                   We note your proposed
revised disclosures in response to prior comment 3. While we
                                                        acknowledge that you
have quantified the percentage change in your various revenue
                                                        streams, your proposed
disclosure does not quantify the underlying factors that
                                                        contributed to the
change in your lease license license, perpetual license, service or
                                                        maintenance revenues.
For example, you state that the increase in lease license revenue
                                                        was driven by growth in
existing multi-year licenses and a shift toward multi-year lease
                                                        products from annual
product sales. Please further revise to quantify the underlying
                                                        factors that
contributed to the change in each revenue stream. Also, refrain from using
                                                        terms such as
"primarily" in lieu of providing more specific quantitative disclosure. Refer
                                                        to Item 303(b) of
Regulation S-K.
 Nicole Anasenes
December 13, 2022
Page 2

       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.

FirstName LastNameNicole Anasenes
                                                         Division of
Corporation Finance
Comapany NameANSYS Inc.
                                                         Office of Technology
December 13, 2022 Page 2
cc:       Brad Brasser, Esq.
FirstName LastName