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 May 9, 2025

Praveer Melwani
Chief Financial Officer
Figma, Inc.
760 Market Street, Floor 10
San Francisco, CA 94102

 Re: Figma, Inc.
 Draft Registration Statement on Form S-1
 Submitted April 15, 2025
 CIK No. 0001579878
Dear Praveer Melwani:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1 submitted April 15, 2025
Prospectus Summary, page 1

1. We note your disclosure that Figma AI leverages a mix of
off-the-shelf foundational
 models and self-hosted models that we develop and train on
design-specific concepts
 to make our features more efficient and effective . Please revise to
quantify how
 much third- party models do you rely on for your AI features on your
platform.
2. We note your references to critics of you company's design process. For
proper
 context, you should identify what the primary criticisms were.
3. We note your statement that you intend to announce material information
through a
 variety of mediums following effectiveness, and that this information
could be
 material information. You also encourage investors to follow your
announcements
 through these mediums; however, you also caution investors not to rely
upon any such
 May 9, 2025
Page 2

 information in deciding whether to purchase your stock. Please clarify
the point of
 encouraging investors to consider this information but not to rely upon
it in making an
 investment decision.
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 80

4. Throughout your MD&A you refer to several plan offerings including
Organization,
 Enterprise, Professional and Free. To enhance investor understanding of
your
 business, please provide a comprehensive comparative discussion of each
plan level.
 Such discussion should include at a minimum a description of the
products and
 services included, the pricing, and the approximate number of customers
and users at
 each level.
5. We note on page 81 you indicate that you have more than 400,000 paid
customers as
 of December 31, 2024. We also note on page 83 you indicate that during
the three
 months ended December 31, 2024, you had over twelve million monthly
active users.
 Please discuss the relationship between paid customers and active users.
In addition,
 clarify how you calculate the number of monthly active users during a
three month
 period.
Annual Recurring Revenue, page 82

6. On page 82 you indicate that you calculate annual recurring revenue
(ARR) as the
 annualized value of your active customer agreements as of the
measurement date,
 assuming any agreement that expires during the next twelve months
following the
 measurement date is renewed on existing terms. Please tell us your
consideration of
 the impact of known terminations and cancellations on your calculation
of ARR.
March Pricing and Packaging Update, page 82

7. We note your disclosure that in March 2025 you made your first-ever
changes to the
 pricing and packaging of your plans. You further disclose that customers
can now
 purchase multi-product seats and these changes give administrators
better tools and
 even greater control of managing their teams. Please describe the
typical packages
 offered prior to the pricing and packaging update compared to the
typical packages
 offered subsequent to the March 2025 changes. Please also disclose the
approximate
 rate of price increases.
Gross Retention Rate, page 84

8. We note your disclosure that your gross retention rate was 97% as of
December 31,
 2024 and that it demonstrates that the vast majority of your customers
renew their
 subscriptions. Tell us whether you consider gross retention rate to be a
key metric that
 the Company s management uses to manage the business, and if so,
revise to include
 key business metric disclosures for this measure in your MD&A. Refer to
SEC
 Release No. 33-10751.
Net Dollar Retention Rate, page 87

9. Please expand your disclosure in regard to net dollar retention rate to
discuss factors
 that contributed to the quarter-over-quarter contraction of the rate
throughout 2023.
 May 9, 2025
Page 3

Intellectual Property, page 120

10. We note your disclosure that you own 14 issued US patents. Please
clarify the type of
 patent protection, whether they are owned or licensed and the product
groups and
 technologies that such patents relate.
General

11. Please supplementally provide us with copies of all written
communications, as
 defined in Rule 405 under the Securities Act, that you, or anyone
authorized to do so
 on your behalf, present to potential investors in reliance on Section
5(d) of the
 Securities Act, whether or not they retain copies of the communications.
 Please contact Anastasia Kaluzienski at 202-551-3685 or Robert
Littlepage at 202-
551-3361 if you have questions regarding comments on the financial statements
and related
matters. Please contact Uwem Bassey at 202-551-3433 or Larry Spirgel at
202-551-3815
with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Ran D. Ben-Tzur
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