December 11, 2007

Via U.S. Mail and Facsimile (650-357-3907)

Guy Gecht
Chief Executive Officer
Electronics For Imaging, Inc.
303 Velocity Way
Foster City, CA 94404

      Re:		Electronics For Imaging, Inc.
      Form 10-K for Fiscal Year Ended December 31, 2006
      Filed October 19, 2007
			File No. 0-18805

Dear Mr. Gecht:

      We have limited our review of your above filings to
disclosure
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we have the following comments.
Our
review with respect to this issue does not preclude further review
by
the Assistant Director group with respect to other issues.  At
this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. After
reviewing
this information, we may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General
1. You state on pages 28 and 98-99 of your Form 10-K that you
and/or
your subsidiary, VUTEk, may have violated regulations administered
by
the Commerce Department`s Bureau of Industry and Security (BIS)
with
regards to Iran and Syria, countries identified as state sponsors
of
terrorism by the State Department and subject to U.S. economic
sanctions and export controls.  Please advise us of any updated
information you have regarding the BIS investigation.
2. Please describe for us the nature and extent of your past, and
any
current or anticipated, contacts with Iran, whether through direct
or
indirect arrangements.  Describe in reasonable detail the
products,
technologies, and services you or VUTEk have provided or
anticipate
providing into Iran.
Please update the  information you provided the Staff regarding
your
contacts with Syria in your letter dated June 30, 2006, to include
any information available subsequent to your compliance review
that
was not reflected in that letter, regarding (i) the nature and
extent
of your past, and any current or anticipated, contacts with Syria;
and (ii) the products, technologies and services you or VUTEk have
provided or anticipate providing into Syria.
Your response should include description and discussion of the
deemed
export of controlled encryption source code and/or technology to
nationals of Iran and Syria, and the export of printers and other
products with encryption functionality without prior BIS review.
Finally, describe any agreements, commercial arrangements, or
other
contacts with the government of Iran or Syria or entities
controlled
by those governments.
3. Please discuss the materiality of the contacts described in
response to the foregoing comments, and whether they would
constitute
a material investment risk for your security holders. You should
address materiality in quantitative terms, including, for each
referenced country, the approximate dollar amounts of any
associated
revenues, assets, and liabilities for the last three years.
Please
also address materiality in terms of qualitative factors that a
reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities
upon
a company`s reputation and share value.

We note, for example, that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Missouri Investment Trust has established an
equity
fund for the investment of certain state-held monies that screens
out
stocks of companies that do business with U.S.-designated state
sponsors of terrorism.  The Pennsylvania legislature has adopted a
resolution directing its Legislative Budget and Finance Committee
to
report annually to the General Assembly regarding state funds
invested in companies that have ties to terrorist-sponsoring
countries.  Your materiality analysis should address the potential
impact of the investor sentiment evidenced by such actions
directed
toward companies that have business contacts with Iran and Syria.

Your qualitative materiality analysis also should address whether,
and the extent to which, the governments of the referenced
countries,
or persons or entities controlled by those governments, receive
cash
or act as intermediaries in connection with your contacts.

* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please submit
your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comments.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review.  You may also contact me at (202) 551-
3470.

								Sincerely,



								Cecilia Blye, Chief
								Office of Global Security
Risk

cc: 	Barbara Jacobs
		Assistant Director
	Division of Corporation Finance
Guy Gecht
Electronics For Imaging, Inc.
December 11, 2007
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