United States securities and exchange commission logo October 26, 2020 Gregory S. Bentley Chief Executive Officer Bentley Systems, Incorporated 685 Stockton Drive Exton, PA 19341 Re: Bentley Systems, Incorporated Draft Registration Statement on Form S-1 Submitted October 23, 2020 CIK No. 0001031308 Dear Mr. Bentley: This is to advise you that we do not intend to review your registration statement. We request that you publicly file your registration statement no later than 48 hours prior to the requested effective date and time. Please refer to Rule 461 regarding requests for acceleration. 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. Please contact Jeff Kauten, Attorney-Advisor, at (202) 551-3447, or in his absence, Jan Woo, Legal Branch Chief, at (202) 551-3453, with any questions. If you require further assistance, please contact Larry Spirgel, Office Chief, at (202) 551-3815. Sincerely, Division of Corporation Finance Office of Technology cc: Richard Fenyes, Esq.