United States securities and exchange commission logo April 13, 2023 Chantelle Breithaupt Chief Financial Officer Aspen Technology, Inc. 20 Crosby Drive Bedford, Massachusetts 01730 Re: Aspen Technology, Inc. Form 10-KT for the Transition Period from October 1, 2021 to June 30, 2022 File No. 001-41400 Dear Chantelle Breithaupt: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Technology