SecProbe.io

April 30 , 2013

Via E -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 Fiscal Year Ended  December  31, 2012
Filed February 27, 2013
File No.: 001-12031

Dear Mr. Rosenblatt :

We have reviewed your filing s and have the following comment s.  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents.  In some of our comments, we may ask you to provide
us with information so we may better unders tand your disclosure.

Please respond to this letter within ten business days by provi ding the requested
information or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for the Year Ended Dece mber 31, 2012

Index to Consolidated Financial Statements, page F -1

Note 2.  Summary of Significant Accounting Policies, page F -11

-Revenue Recognition and Deferred Revenue, page F -15

1. We note from page 37 that SDC is paying you a fixed license fee, paya ble in semi -annual
installments over the agreement term and that you will recognize license fee reven ue
under this agreement as the  installment payments become due and payable since you
believe such payment amounts are not considered fixed and determinable  for reve nue
recognition purposes until  they become due and payable.  Please tell us the U.S. GAAP
you considered when determining how to account for license fees from SDC.  E xplain to
us in more detail why you recognize revenue from SDC when the installme nts become

Mr. Sidney D. Rosenblatt
Universal Display Corporation
April 30 , 2013
Page 2

 due and payable under  your SDC licensing agreement and why you believe the amounts
due from SDC are not  fixed or determinable  until they become due and payable . Please
address your consideration of  the guidance in SAB Topic 13 , including paragra ph A(4)
thereof, in your response to this comment .

Note 13.  Commitments and Contingencies, page F -28

-Patent Related Challenges and Oppositions , page F-29

2. We note your disclosures here regarding your patent related challenges and oppositions .
You state that you do not believe that the “confirmation, loss or modification of [your]
rights in any individual claim or set of claims that are the subject of the following legal
proceedings would have a material impact on [your] material sales or lic ensing business .”
Please revise future filings to disclose your assessment of the expected materiality of all
known loss contingencies  on your financial statements as a whole, including your
consolidated statement of operations.  Refer to the guidance in 450-20-50 of the FASB
Accounting Standards Codification.

3. Further to the above, we note your disclosures related to certain of the individual patent
matters whereby you are experiencing challenges and oppositions.  It is unclear from
your disclosure if you  have accrued for any of these matters within your financial
statements.  For instance, we note that the Japanese IP High Court upheld the decision of
the JPO for Japan Patent No. 3992929.  Please tell us and revise your future filings to
explain if you ha ve accrued for any of the matters as of December 31, 2012 and the basis
for your conclusions.  Refer to the guidance in 450 -20 of the FASB Accounting
Standards Codification.

Note 14.  Concentration of Risk, page F -32

4. We see your disclosure of long -lived assets (net) by geographic area includes acquired
technology.  Please tell us why you believe including intangibles in the referenced
disclosures is consistent with the guidance at 280 -10-55-23 of the FASB Accounting
Standards Codification.  Revise these  disclosures in future filings to comply with the
referenced literature or tell us why you believe no revisions to your future disclosures are
necessary.

Exhibits 31.1 and 31.2

5. In future filings, please include the title of each individual beneath their signature on
these certifications.  Refer to Item 601(b)(31) of Regulation S -K.

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 E xchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are

Mr. Sidney D. Rosenblatt
Universal Display Corporation
April 30 , 2013
Page 3

 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 provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Tara Harkins, Staff Accountant, at (202) 551 -3639 or Jay Webb, Reviewin g
Accountant, at (202) 551 -3603 if you have questions regarding these comments.  In this regard,
do not hesitate to contact me at (202) 551 -3643.

       Sincerely,

       /s/ Jay Webb “for”

        Kevin L. Vaughn
        Accounting Branch Chief