BMC Software, Inc.
2101 CityWest Blvd.
Houston, TX 77042

November 14, 2007

VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Room 4561
Washington, D.C. 20549

Attention:      Megan Akst, Staff Accountant

Re: BMC Software, Inc.
Form 10-K for Fiscal Year Ended March 31, 2007
File No. 001-16393

Dear Megan:

     On November 12, 2007, BMC Software, Inc. (the “Company”) received the comment letter from the Staff of the Securities and Exchange Commission dated October 30, 2007 with respect to the above-referenced Company filing. Due to the upcoming Thanksgiving holiday week and subsequent international travel plans of various key personnel involved in preparing the Company’s response, the Company respectfully requests an extension to the initial reply deadline to Friday, December 7, 2007.

     If this request causes the Staff concern or you have any questions regarding it, please do not hesitate to contact the undersigned at 713-918-3559.

Very truly yours,
 

/s/ Christopher C. Chaffin  

Christopher C. Chaffin 

Vice President, Deputy General Counsel & Assistant Secretary