March 2, 2020

Antonio Pietri
President and Chief Executive Officer
Aspen Technology Inc.
20 Crosby Drive
Bedford, MA 01730

       Re: Aspen Technology Inc.
           Form 10-K for Fiscal Year Ended June 30, 2019
           Filed September 10, 2019
           File No. 001-34630

Dear Mr. Pietri:

       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 Fiscal Year Ended June 30, 2019

Note 3. Revenue from Contracts with Customers
Contract Balances, page F-18

1.     Please describe in your future contract balances policy disclosure:
         when and how you recognize a contract asset;
         the significant payment terms of your contracts in accordance with ASC
606-10-50-
           12(b);
         your policy for the timely recognition and measurement of an
impairment of a
           contract asset in accordance with Topic 310; and
         how the timing of satisfaction of performance obligations relates to
the timing of
           payment and the effect on the contract asset and liability balances
in accordance with
           ASC 606-10-50-9.
       As part of your response, provide us a draft of your anticipated
disclosure.
 Antonio Pietri
Aspen Technology Inc.
March 2, 2020
Page 2
Note 19. Quarterly Financial Data (Unaudited)
Restatement of the Fiscal 2019 Unaudited Quarterly Financial Statements, page
F-38

2.       Please explain to us the facts and circumstances concerning your
correction of the errors
         in your prior period financial statements. As part of your response,
please include:
           a detailed description of the nature of the errors, especially in
regard to your
             application of accounting guidance to contract asset balances;
           the basis for your conclusion that there was an error in your
adoption of ASC 606 and
             not, in fact, an impairment loss that should have been reported in
your income
             statement;
           an explanation of why the errors in the balance sheet amounts, such
as the
             overstatement of contract assets and accounts receivable, do not
result in a
             corresponding income statement error such as an overstatement of
prior period
             revenue;
           your analysis of the materiality of the errors; and
           an explanation of how you applied the restatement guidance when
accounting for the
             correction of an error, in particular, why you decided not to
amend previously issued
             financial statements. Please refer to ASC 250-10-45 and Staff
Accounting Bulletins
             No. 99 and No. 108.

       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 Joseph Cascarano, Senior Staff Accountant, at (202)
551-3376 or
Robert S. Littlepage, Accountant Branch Chief, at (202) 551-3361 with any
questions.



FirstName LastNameAntonio Pietri                             Sincerely,
Comapany NameAspen Technology Inc.
                                                             Division of
Corporation Finance
March 2, 2020 Page 2                                         Office of
Technology
FirstName LastName