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corresp

Universal Display Corporation

375 Phillips Boulevard

Ewing, NJ 08618

April 29, 2009

Via EDGAR and Facsimile

Securities and Exchange Commission

Judiciary Plaza

100 F Street, N.E.

Washington, DC 20549

Attention: Geoffrey Kruczek, Esquire

    Re:

    Universal Display Corporation (the “Company”)

Registration Statement on Form S-3 (Filing No. 333-157926)

Dear Mr. Kruczek:

This letter is being submitted in response to the comment given by the staff of the Division of
Corporation Finance of the Securities and Exchange Commission (the “Commission”) as set forth in
your letter to Steven V. Abramson, President and Chief Executive Officer of Universal Display
Corporation (the “Company”), dated March 26, 2009, with respect to the above-referenced
registration statement (the “Registration Statement”).

In addition, as per your telephone conversation on April 28, 2009 with our counsel, Justin W.
Chairman of Morgan, Lewis & Bockius LLP, and in accordance with Rule 461 under the Securities Act
of 1933, as amended, the Company hereby requests the acceleration of the effective date of the
above-referenced Registration Statement so that it will become effective on Friday, May 1, 2009, at
12:00 p.m. Eastern Time or as on thereafter as practicable.

For your convenience, we have set forth the comment in italicized typeface and included the
response below the comment.

General

    1.

    We note that you have incorporated by reference your annual report on Form 10-K into this
Form S-3. We also note that the information required by Part III of Form 10-K was not provided
in that filing, but will be incorporated by reference from your proxy statement. Please note
that before you request that the effective date of this registration statement be accelerated,
you should either (1) file your definitive proxy statement with all required information; or
(2) file an amendment to your Form 10-K to include the information required by Part III.
Refer to Question 123.01 of the Division of Corporation Finance’s Compliance and Disclosure
Interpretations, available on our website at http://sec.gov/divisions
/corpfin/guidance/safinterp.htm.

          The Company notes that on April 24, 2009, it filed with the Commission its definitive proxy
statement for the annual meeting of shareholders to be held in 2009, which definitive proxy
statement includes the information required by Part III of Form 10-K.

Pursuant to the letter dated March 26, 2009 from Peggy Fisher of the Staff to Steven V. Abramson of
the Company, in connection with this request for effectiveness, the Company acknowledges the
following:

The disclosure in the filing is the responsibility of the Company. The Company
represents to the Commission that should the Commission or the staff acting pursuant
to delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing and the Company
represents that it will not assert this action as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

The Company further acknowledges, that the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the filing effective does not
relieve the Company from its full responsibility for the adequacy and accuracy of
the disclosures in the filing.

    Sincerely yours,

Universal Display Corporation

    By:
    /s/ Scott C. Bovino

    Scott C. Bovino

    Vice President and General Counsel

cc:     Justin W. Chairman, Esquire