SEC Comment Letter for UNIVERSAL DISPLAY CORP \PA\ (OLED) — Apr 26, 2011
UNIVERSAL DISPLAY CORP \PA\
Date: April 26, 2011 · CIK: 0001005284 · Accession: 0000000000-11-025765
AI Filing Summary & Sentiment
File numbers found in text: 001-12031
Referenced dates: April 21, 2011
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
April 26, 2011
Via Facsimile and U.S. Mail
Mr. Sidney D. Rosenblatt Chief Financial Officer Universal Display Corporation 375 Phillips Boulevard Ewing, New Jersey 08618
Re: Universal Display Corporation
Form 10-K for the Year Ended December 31, 2010 Filed March 16, 2011 File No. 001-12031
Dear Mr. Rosenblatt:
We have reviewed your response letter dated April 21, 2011 and have the following
comment. In our comment, we may ask you to provi de us with information so we may better
understand your disclosure.
Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your
response.
After reviewing the information you provide in response to this comment, we may have
additional comments.
Mr. Sidney D. Rosenblatt
Universal Display Corporation April 26, 2011 Page 2
General
1. Please provide the three acknow ledgements included at the end of our April 7, 2011
comment letter. For your reference, we ha ve repeated the acknowledgements below.
Please note that the acknowledgements must be provided by an authorized officer of the
Company.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in
the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provi de a written statement from the company
acknowledging that:
the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of the United States.
You may contact Tara Harkins, Staff Accountant, at (202) 551-3639 or me at (202) 551-3643
if you have questions regarding thes e comments. In this regard, do not hesitate to contact Martin
James, Senior Assistant Chief Accountant, at (202) 551-3671.
S i n c e r e l y ,
Kevin L. Vaughn A c c o u n t i n g B r a n c h C h i e f