November 10, 2020

 

VIA EDGAR

 

	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.

 

[Signature Page Follows]

 

 

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