November 10, 2020




Re:Bentley Systems, Incorporated
  Registration Statement on Form S-1
  File No. 333-250002


Division of Corporation Finance

Office of Technology

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

c/o Jeffrey Kauten


Ladies and Gentlemen:


Pursuant to Rule 461 under the Securities Act of 1933, as amended, Bentley Systems, Incorporated (the “Company”) hereby requests that the effective date of the above-referenced Registration Statement be accelerated so that it may become effective at 4:00 p.m., New York, NY time, on November 12, 2020, or as soon as possible thereafter. In this regard, the Company is aware of its obligations under the Securities Act.


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  Very truly yours,
  By: /s/ David R. Shaman
    Name:  David R. Shaman
    Title:  Chief Legal Officer and Corporate Secretary