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 Document July 29, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F. Street, N.E. Washington, D.C. 20549 Attention: Uwem Bassey Larry Spirgel Anastasia Kaluzienski Robert Littlepage Re: Figma, Inc. Registration Statement on Form S-1, as amended File No. 333-288451 Acceleration Request Requested Date: July 30, 2025 Requested Time: 4:00 P.M. Eastern Time To the addressees set forth above: In accordance with Rule 461 under the Securities Act of 1933, as amended (the “ Securities Act ”), we, as representatives of the several underwriters, hereby join in the request of Figma, Inc. (the “ Company ”) for acceleration of the effective time of the above-referenced registration statement (the “ Registration Statement ”), requesting effectiveness as of 4:00 P.M., Eastern Time, on July 30, 2025, or at such later time as the Company or its outside counsel, Fenwick & West LLP, may request via telephone call to the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission. Pursuant to Rule 460 under the Securities Act, we, as representatives of the several underwriters, wish to advise you that we will take reasonable steps to secure adequate distribution of the preliminary prospectus to underwriters, dealers, institutions and others prior to the requested effective time of the Registration Statement. We, the undersigned, as representatives of the several underwriters, have complied and will comply, and we have been informed by the participating underwriters that they have complied and will comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [ Signature page follows ] Very truly yours, MORGAN STANLEY & CO. LLC GOLDMAN SACHS & CO. LLC ALLEN & COMPANY LLC As representatives of the several underwriters MORGAN STANLEY & CO. LLC By: /s/ Rizvan Dhalla Name: Rizvan Dhalla Title: Managing Director GOLDMAN SACHS & CO. LLC By: /s/ Charlie Black Name: Charlie Black Title: Managing Director ALLEN & COMPANY LLC By: /s/ Peter DiIorio Name: Peter DiIorio Title: General Counsel [Signature Page to Underwriters’ Acceleration Request]

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 Document Figma, Inc. 760 Market Street, Floor 10 San Francisco, CA 94102 July 29, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, N.E. Washington, D.C. 20549 Attention: Uwem Bassey Larry Spirgel Anastasia Kaluzienski Robert Littlepage Re: Figma, Inc. Registration Statement on Form S-1, as amended (File No. 333-288451) Request for Acceleration of Effective Date Requested Date: July 30, 2025 Requested Time: 4:00 PM Eastern Time Ladies and Gentlemen: In accordance with Rule 461 under the Securities Act of 1933, as amended, Figma, Inc. (the “ Registrant ”) hereby requests that the U.S. Securities and Exchange Commission take appropriate action to declare the above-captioned Registration Statement on Form S - 1 effective at the “Requested Date” and “Requested Time” set forth above or as soon thereafter as practicable. The Registrant hereby authorizes Ran Ben-Tzur and Michael Esquivel, each of whom are attorneys with the Registrant’s outside legal counsel, Fenwick & West LLP, to orally modify or withdraw this request for acceleration. The Registrant requests that it be notified of such effectiveness by a telephone call to Mr. Ben-Tzur at (650) 335-7613, or in his absence, Mr. Esquivel at (650) 335-7913. Sincerely, FIGMA, INC. By: /s/ Dylan Field Dylan Field Chief Executive Officer and President cc: Praveer Melwani, Chief Financial Officer Brendan Mulligan, Esq., General Counsel and Secretary Figma, Inc. Ran Ben-Tzur, Esq. Jennifer Hitchcock, Esq. Aman Singh, Esq. Fenwick & West LLP Richard A. Kline, Esq. Richard Kim, Esq. Latham & Watkins LLP

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 Document July 21, 2025 VIA EDGAR AND ELECTRONIC TRANSMISSION U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, NE Washington, DC 20549 Attention: Uwem Bassey Larry Spirgel Anastasia Kaluzienski Robert Littlepage Re: Figma, Inc. Registration Statement on Form S-1 Filed July 1, 2025 Ladies and Gentlemen: We are submitting this letter on behalf of Figma, Inc. (the “ Company ”) in response to the comments of the staff (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ Commission ”) contained in the Staff’s letter dated July 15, 2025 (the “ Letter ”) regarding the Company’s Registration Statement on Form S-1 (File No. 333-288451) initially filed by the Company with the Commission on July 1, 2025. Concurrently herewith, we are filing a copy of the Company’s Amendment No. 1 to the Registration Statement on Form S-1 (“ Amendment No. 1 ”). The numbered paragraphs below correspond to the numbered comments in the Letter and the Staff’s comments are presented in bold italics. In addition to addressing the comments raised by the Staff in the Letter, the Company has revised Amendment No. 1 to update certain other disclosures. Capitalized terms used and not otherwise defined herein have the same meanings as specified in Amendment No. 1. Form S-1 file July 1, 2025 Prospectus Summary, page 2 1. We refer to your graphic presentation of non-GAAP operating margin on page 2 and elsewhere in your filing. Please revise to also present, with equal or greater prominence, the most directly comparable GAAP financial measure. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Division of Corporation Finance’s Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. In response to the Staff’s comment, the Company has revised its disclosure in the cover art and on pages 2 and 155 of Amendment No. 1. U.S. Securities and Exchange Commission July 21, 2025 Page 2 Notes to the Consolidated Financial Statements Note 17. Subsequent Events (Unaudited), page F-51 2. We note your expanded subsequent events disclosures regarding additional RSU grants on May 28, 2025 and June 30, 2025. Please revise to disclose the estimated stock-based compensation expense that will impact your future financial statements. Refer to ASC 855-10-50-2(b). In addition, please include a full discussion of such grants and related estimated stock-based compensation expense in your discussion of significant impacts of stock-based compensation on page 143. In response to the Staff’s comment, the Company has revised its disclosure on pages 144 and F-51 of Amendment No. 1 . * * * * * * * Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact me at (650) 335-7613, or in my absence, Michael Esquivel at (650) 335-7913. Sincerely, /s/ Ran Ben-Tzur Ran Ben-Tzur Partner FENWICK & WEST LLP cc: Dylan Field, Chief Executive Officer and President Praveer Melwani, Chief Financial Officer Brendan Mulligan, Esq., General Counsel and Corporate Secretary Figma, Inc. Michael Esquivel, Esq. Jennifer Hitchcock, Esq. Aman Singh, Esq. Fenwick & West LLP Richard A. Kline, Esq. Richard Kim, Esq. Latham & Watkins LLP

<DOCUMENT>
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<TEXT>
 July 15, 2025

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

 Re: Figma, Inc.
 Registration Statement on Form S-1
 Filed July 1, 2025
 File No. 333-288451
Dear Praveer Melwani:

 We have reviewed your 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.

Form S-1 filed July 1, 2025
Prospectus Summary, page 2

1. We refer to your graphic presentation of non-GAAP operating margin on
page 2 and
 elsewhere in your filing. Please revise to also present, with equal or
greater
 prominence, the most directly comparable GAAP financial measure. Refer
to Item
 10(e)(1)(i)(A) of Regulation S-K and Question 102.10(a) of the Division
of
 Corporation Finance s Compliance and Disclosure Interpretations on
Non-
 GAAP Financial Measures.
Notes to the Consolidated Financial Statements
Note 17. Subsequent Events (Unaudited), page F-51

2. We note your expanded subsequent events disclosures regarding additional
RSU
 grants on May 28, 2025 and June 30, 2025. Please revise to disclose the
estimated
 stock-based compensation expense that will impact your future financial
statements.
 July 15, 2025
Page 2

 Refer to ASC 855-10-50-2(b). In addition, please include a full
discussion of such
 grants and related estimated stock-based compensation expense in your
discussion of
 significant impacts of stock-based compensation on page 143.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 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
</TEXT>
</DOCUMENT>

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 Document July 1, 2025 VIA EDGAR AND ELECTRONIC TRANSMISSION U.S. Securities and Exchange Commission Division of Corporation Finance Office of Technology 100 F Street, NE Washington, DC 20549 Attention: Uwem Bassey Larry Spirgel Anastasia Kaluzienski Robert Littlepage Re: Figma, Inc. Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted May 23, 2025 CIK No. 0001579878 Ladies and Gentlemen: We are submitting this letter on behalf of Figma, Inc. (the “ Company ”) in response to the comments of the staff (the “ Staff ”) of the U.S. Securities and Exchange Commission (the “ Commission ”) contained in the Staff’s letter dated June 9, 2025 (the “ Letter ”) regarding the Company’s Amendment No. 1 to Draft Registration Statement on Form S-1 (CIK No. 0001579878) confidentially submitted by the Company to the Commission on May 23, 2025. Concurrently herewith, we are filing a copy of the Company’s Registration Statement on Form S-1 (the “ Registration Statement ”). The numbered paragraphs below correspond to the numbered comments in the Letter and the Staff’s comments are presented in bold italics. In addition to addressing the comments raised by the Staff in the Letter, the Company has revised the Registration Statement to update certain other disclosures. Capitalized terms used and not otherwise defined herein have the same meanings as specified in the Registration Statement. 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. In response to the Staff’s comment, the Company has revised its disclosure on page 33 of the Registration Statement. Capitalization, page 85 U.S. Securities and Exchange Commission July 1, 2025 Page 2 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. In response to the Staff’s comment, the Company has revised its disclosure on page 100 of the Registration Statement . 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. In response to the Staff’s comment, the Company has revised its disclosure on pages 119 and 120 of the Registration Statement . 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. In response to the Staff’s comment, the Company has revised its disclosure on page 143 of the Registration Statement . * * * * * * * Should the Staff have additional questions or comments regarding the foregoing, please do not hesitate to contact me at (650) 335-7613, or in my absence, Michael Esquivel at (650) 335-7913. U.S. Securities and Exchange Commission July 1, 2025 Page 3 Sincerely, /s/ Ran Ben-Tzur Ran Ben-Tzur Partner FENWICK & WEST LLP cc: Dylan Field, Chief Executive Officer and President Praveer Melwani, Chief Financial Officer Brendan Mulligan, Esq., General Counsel and Corporate Secretary Figma, Inc. Michael Esquivel, Esq. Jennifer Hitchcock, Esq. Aman Singh, Esq. Fenwick & West LLP Richard A. Kline, Esq. Richard Kim, Esq. Latham & Watkins LLP

<DOCUMENT>
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<TEXT>
 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
</TEXT>
</DOCUMENT>

<DOCUMENT>
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<TEXT>
 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
</TEXT>
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