United States securities and exchange commission logo

                               June 29, 2020

       Bryan Rowland
       General Counsel
       Vertex, Inc.
       2301 Renaissance Blvd.
       King of Prussia, PA 19406

                                                        Re: Vertex, Inc.
                                                            Amendment No. 2 to
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted June 18,
                                                            File No. 377-03104

       Dear Mr. Rowland:

             We have reviewed your amended draft registration statement 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 this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your

              After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments. Unless otherwise noted, where prior comments are referred to
they refer to our letter
       dated May 26, 2020.

       Amendment No. 2 to Draft Registration Statement submitted on June 18,

       Use of Proceeds, page 40

   1.                                                   We note your response
to prior comment 3. Since the company obtained the term loan to
                                                        pay a dividend to
shareholders, and the proceeds of the offering will be used to repay
                                                        the term loan, please
quantify the amount of the dividend paid to your officers, directors
                                                        and affiliates. In
addition, as you state on page 72, disclose that the term loan is required
                                                        to be repaid upon
consummation of the offering.
 Bryan Rowland
Vertex, Inc.
June 29, 2020
Page 2
Consolidated Balance Sheets, page F-3

2.    Please explain the classification of the funds held for stockholder
distributions in
      noncurrent assets in the consolidated balance sheet. In this regard, you
indicate on page
      F-10 that the funds are reserved for distribution to stockholders to be
paid within 90 days
      of March 31, 2020, and if a distribution is not made within this time
frame, such amount
      must be repaid to the bank.
Notes to Consolidated Financial Statements
Note 1. Summary of significant accounting policies
Segments, page F-9

3.    We note that 19% of your long-lived assets are now held outside of the
U.S. Please revise
      to disclose the general nature of the risk associated with this
concentration. In this regard,
      explain the nature and location of these assets and the purpose of the
change in location.
      Refer to ASC 275-10-50-20.
       You may contact Becky Chow, Staff Accountant, at (202) 551-6524 or
Melissa Walsh,
Staff Accountant, at (202) 551-3224 if you have questions regarding comments on
the financial
statements and related matters. Please contact Michael C. Foland,
Attorney-Advisor, at (202)
551-6711 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other

FirstName LastNameBryan Rowland
                                                             Division of
Corporation Finance
Comapany NameVertex, Inc.
                                                             Office of
June 29, 2020 Page 2
cc:       Joel Trotter
FirstName LastName