You may, or may not, be surprised that different word processing programs also count words differently. Todd Smith, a Texas civil appellate attorney, put up the results of his comparison of four programs. http://www.texasappellatelawblog.com/

My first few readings of the rule led me to believe that the prayer was not included because it was part of the signature. I think we're now thinking that the prayer is included in the count. Anyone have other thoughts?

I've turned in a couple of briefs since I realized the rule change. I didn't count the prayer.

I also didn't realize until this week that we're supposed to put a word count on motions for extension of time.

Since the prayer isn't specifically excluded from the word count requirement rule (unlike the signature block), I include those words in my total count. See Tex. R. App. P. 9.4(i)(1).

(i)(3) does seem to require a word count even for motions for extension -- but (i)(2) doesn't place a limit on the number of words in such a motion.

So there isn't really anything to comply with.