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 June 9, 2025

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

 Re: Figma, Inc.
 Amendment No. 1 to the Draft Registration Statement on Form S-1
 Submitted May 27, 2025
 CIK No. 0001579878
Dear Praveer Melwani:

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

 Please respond to this letter by amending your registration statement
and providing
the requested information. 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 any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our May 9, 2025
letter.

Amendment No.1 to the Draft Registration Statement on Form S-1
Consolidated Statements of Operations Data, page 22

1. Revise the line item description "Less: net loss attributable to
participating securities"
 to Less: net income attributable to participating securities.
Capitalization, page 85

2. Please revise the amount presented in the total capitalization line item
to exclude the
 amount presented in the cash, cash equivalents, and marketable
securities line item
 and double-underline your cash, cash equivalents, and marketable
securities balance
 so that it is clear that cash, cash equivalents, and marketable
securities is not part of
 your total capitalization.
 June 9, 2025
Page 2

Management's Discussion and Analysis
Net Dollar Retention Rate, page 103

3. We note your revised disclosure in response to prior comment 9
indicating that you
 experienced a decline in your net dollar retention rate throughout 2023
as
 macroeconomic pressure impacted seat expansion. Please expand your
disclosure to:
 describe the macroeconomic pressure and explain how it impacted seat
expansion;
 clarify whether or not the macroeconomic pressure continues to be
present; and
 discuss the impact of customer or seat contraction on your net
dollar retention
 rate, if any.
Contractual Obligations and Commitments, page 124

4. We note the tabular presentation of your consolidated principal cash
obligations as of
 March 31, 2025. We further note your disclosure that the total future
minimum lease
 payments associated with the March 6, 2025 amended lease agreement are
not
 included in the operating lease commitments presented in the table.
However, when
 compared to the operating lease commitments as of December 31, 2024
disclosed on
 page 104 of your prior filing on April 15, 2025, it appears that the
future minimum
 lease payments may be included. Please revise your disclosure, as
appropriate, or
 advise us.
 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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