December 17, 2019

Jeffrey Lucas
President and Chief Financial Officer
EMAGIN CORP
700 South Drive
Suite 201
Hopewell Junction, NY 12533

       Re: EMAGIN CORP
           Form 10-K for Fiscal Year December 31, 2018
           Filed March 28, 2019
           File No. 001-15751

Dear Mr. Lucas:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2018

Report of Independent Registered Public Accounting Firm, page F-16

1.    We note the going concern paragraph included in your auditors' report. It
appears your
      auditor has not expressed their view regarding your ability to continue
as a going concern
      and instead, references the company's conclusion on this matter. If your
auditor
      concluded that substantial doubt existed about your ability to continue
as a going concern,
      please have them revise their report to clarify their conclusion under an
appropriately
      titled paragraph. Please refer to paragraph 13 of AS 2415 for guidance.
If your auditor
      concluded that substantial doubt did not exist about your ability to
continue as a going
      concern, please explain to us the reason for the difference between the
company's
      conclusion and the auditors' conclusion. It appears to us that the
current emphasis-of-a-
      matter paragraph may be confusing since it does not clearly convey the
auditors'
      conclusion or the reason for their conclusion in light of the company's
conclusion.
 Jeffrey Lucas
EMAGIN CORP
December 17, 2019
Page 2
Consolidated Statement of Cash Flows, page F-20

2.       We note from your balance sheets, that inventory balances at year end
did not
         change significantly from 2017 to 2018. Please reconcile for us the
change in inventory
         reflected on your Statement of Cash Flows for 2018 with the change
noted in your balance
         sheets. Although we note you separately present the impairment of
consumer night
         vision business inventory in the reconciliation of your net loss to
net cash used in
         operating activities, we are still unable to reconcile the change in
inventory.
Note 2 - Significant Accounting Policies
Inventories, page F-22

3.       We note your inventory accounting policy included in the notes to your
financial
         statements states that inventories are stated at the lower of cost or
market. We note
         elsewhere in your critical accounting policies, that inventories are
stated on a standard
         cost basis. Please revise your disclosures to correct the
inconsistency regarding your
         inventory accounting policy and ensure your accounting and disclosures
comply with
         ASU 2015-11.
       In closing, 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.

      You may contact Kevin Stertzel at (202) 551-3723 or Anne McConnell at
(202) 551-
3709 with any questions.



FirstName LastNameJeffrey Lucas                                 Sincerely,
Comapany NameEMAGIN CORP
                                                                Division of
Corporation Finance
December 17, 2019 Page 2                                        Office of
Manufacturing
FirstName LastName