SEC Comment Letter for UNIVERSAL DISPLAY CORP \PA\ (OLED) — Jul 6, 2017
UNIVERSAL DISPLAY CORP \PA\
Date: July 6, 2017 · CIK: 0001005284 · Accession: 0000000000-17-023531
AI Filing Summary & Sentiment
File numbers found in text: 001-12031
Letter
Mail Stop 3030 July 5 , 2017 Steven V. Abramson Chief Executive 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, 201 6 Filed February 23 , 2017 Form 10 -Q for Fiscal Quarter Ended March 31, 2017 Filed May 4 , 2017 File No. 001-12031
Dear Mr. Abramson :
We have reviewed your filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10 -Q for Fiscal Quarter Ende d March 31, 2017
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 25
1. Please tell us the reasons that phosphorescent emitter demand was higher for developmental material sales. Also, tell us the reasons for the changes in gross margin percentage for developmental material sales, and why your discussion of gross margin percentage is limited to commercial material sales. Include in your response your analysis of whether these issues should be addressed your Form 10 -Q.
Steven V. Abramson Universal Display Corporation July 5, 2017 Page 2
Please contact Tim Buchmiller at (202) 551 -3635 or me at (202) 551 -3617 with any questions.
Sincerely,
/s/ Russell Mancuso
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Mail Stop 3030 July 5 , 2017 Steven V. Abramson Chief Executive 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, 201 6 Filed February 23 , 2017 Form 10 -Q for Fiscal Quarter Ended March 31, 2017 Filed May 4 , 2017 File No. 001-12031 Dear Mr. Abramson : We have reviewed your filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Form 10 -Q for Fiscal Quarter Ende d March 31, 2017 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 25 1. Please tell us the reasons that phosphorescent emitter demand was higher for developmental material sales. Also, tell us the reasons for the changes in gross margin percentage for developmental material sales, and why your discussion of gross margin percentage is limited to commercial material sales. Include in your response your analysis of whether these issues should be addressed your Form 10 -Q. Steven V. Abramson Universal Display Corporation July 5, 2017 Page 2 Please contact Tim Buchmiller at (202) 551 -3635 or me at (202) 551 -3617 with any questions. Sincerely, /s/ Russell Mancuso Russell Mancuso Branch Chief Office of Electronics and Machinery Justin W. Chairman, Esq. Morgan, Lewis & Bockius LLP