SecProbe.io

June 3 , 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 response letter dated May 23, 2013  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 understand 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 requ ested 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 th e Year Ended December 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 your response to our prior comment 1. Please  revise your future filings to
explain in more detail why you are recognizing license fee revenue from the SCD
licensing agreement as the installment payments become due and payable.   For example,
include a general statement of the authoritative accounting  literature on which your
accounting was based and discuss how the accounting applied was impacted by fact the
agreement conveys a non -exclusive right to use intellectual assets for a limited period of
time that is less than the life of the intellectual pr operty asset as well as the fact the

Mr. Sidney D. Rosenblatt
Universal Display Corporation
June 3 , 2013
Page 2

 agreement contains extended payment terms.   Please provide us with a sample of your
proposed future disclosures.

Note 13.  Commitments and Contingencies, page F -28

-Patent Related Challenges and Oppositions , page F-29

2. We note your response to our prior comment 2.  Based on related disclosures included in
your March 31, 2013 Form 10 -Q and your response to our prior comment, it is unclear if
you are going to provide your assessment of the expected materiality of all kno wn loss
contingencies  on your financial statements as a whole, including your consolidated
statement of operations , in your future filings .  As such, please specifically explain to us
if you will revise your future filings to provide your assessment of the  expected
materiality of all known loss contingencies on your financial statements as a whole. Refer
to the guidance in 450 -20-50 of the FASB Accounting Standards Codification.

3. We note your response to our prior comment 3 and that you have not accrued for  any of
the patent matters outlined in your disclosure. If there is at least a reasonable possibility
that a loss exceeding amounts already recognized may have been incurred  (in your case
zero) , please tell us and revise your future filings to either discl ose an estimate (or, if true,
state that the estimate is immaterial in lieu of providing  quantified amounts) of the
additional loss or range of loss, or state that such an  estimate cannot be made  for each of
these matters . Please refer to 450 -20-50 of the FASB Accounting Standards Codification.

You may contact Tara Harkins, Staff Accountant, at (202) 551 -3639 or Jay Webb, Reviewing
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