SecProbe.io

May 2, 2012
Via E-mail
Steven V. Abramson President and Chief Executive Officer Universal Display Corporation 375 Phillips Boulevard Ewing, NJ 08618
Re: Universal Display Corporation
 Form 10-K for Fiscal Year Ended December 31, 2011
Filed February 28, 2012 File No. 001-12031

Dear Mr. Abramson:
 We have reviewed your filing 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 within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Please revise future filings in response to each of the comments below.  Please also
supply us with a draft of your  proposed disclosures.
            Item 1. Business, page 2

1. It appears that your business relies primarily on commercializa tion of your “proprietary
emitter materials” and, to a lesser extent , your “proprietary phosphorescent host
materials,” either through direct sales of  the materials or li censing of the underlying
intellectual property.  Please clearly address your position within the OLED industry.  It
might be helpful, in this regard, to disc uss briefly the OLED stack, different emitter
material colors and how your OLED materi als and technologies operate within this
architecture.
 2. Please address more clearly the competi tive landscape within the OLED industry,
including the bases upon which you compete with  other suppliers of OLED materials and
technologies.  Please refer to Re gulation S-K, Item 101(c)(1)(x).

Steven V. Abramson Universal Display Corporation May 2, 2012 Page 2

3. Please explain in more detail the general availability of raw materials necessary to
produce your OLED materials.  We note th at “key raw materials are sourced from
multiple suppliers;” however, your disclosure sh ould address also the general availability
of essential raw materials.
Item 3. Legal Proceedings, page 22

 4. Please revise to address whether any of the actions listed concern intellectual property
related to your key PHOLED technology or any other intellectual property that is
essential to commercializing your O LED materials or technologies.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s 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.

Please contact Joseph McCann at (202) 551- 6262 or me at (202) 551-3528 with any
questions.
Sincerely,
   /s/ Amanda Ravitz
Amanda Ravitz Assistant Director
  cc (via E-mail): Justin W. Chairman, Esq. - Morgan, Lewis & Bockius LLP