SEC Comment Letter for 3D SYSTEMS CORP (DDD) (CIK 0000910638) (DDD) — Jun 15, 2012
3D SYSTEMS CORP (DDD) (CIK 0000910638)
Date: June 15, 2012 · CIK: 0000910638 · Accession: 0000000000-12-031340
AI Filing Summary & Sentiment
Reasoning
Letter
June 15, 2012 Via E -mail Abraham N. Reichental President and CEO 3D Systems Corporation 333 Three D Systems Circle Rock Hill, SC 29730
Re: 3D Systems Corporation Form 10-K Filed February 23, 2012 File No. 001 -34220
Dear Mr. Reichental :
We have reviewed your filing an d have the following comment. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our 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 filing and the information you provide in response to our comment , we may have additional comments.
Part III (incorporated by reference from the Definitive Proxy Statement filed on March 30, 2012
Security Ownership of Certain Beneficial Owners and Management, page 39
1. Please advise who holds the voting and dispositive power over the shares of your common stock held by the Clark Estates, Inc. If Mr. Moore holds or shares such power, please advise why the 2,836,464 shares held b y the Clark Estates are not included in his individual holdings (and in the holdings of all directors and officers as a group) in the beneficial ownership table. Refer to Item 403 of Regulation S -K.
We urge all persons who are responsible for the accur acy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
Abraham N. Reichental 3D Systems Corporation June 15, 2012 Page 2
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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.
If you have any qu estions regarding our comment , please contact Matthew Crispino, Staff Attorney, at (202) 551 -3456 or, in his absence, me at (202) 551 -3462 . Should you require further assistance, you may contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3735.
Sincerely,
/s/ Mark P. Shuman
Show Raw Text
June 15, 2012
Via E -mail
Abraham N. Reichental
President and CEO
3D Systems Corporation
333 Three D Systems Circle
Rock Hill, SC 29730
Re: 3D Systems Corporation
Form 10-K
Filed February 23, 2012
File No. 001 -34220
Dear Mr. Reichental :
We have reviewed your filing an d have the following comment. Please respond to this
letter within ten business days by amending your filing, by providing the requested information,
or by advising us when you will provide the requested response. If you do not believe our
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 filing and the information you provide in
response to our comment , we may have additional comments.
Part III (incorporated by reference from the Definitive Proxy Statement filed on March 30, 2012
Security Ownership of Certain Beneficial Owners and Management, page 39
1. Please advise who holds the voting and dispositive power over the shares of your
common stock held by the Clark Estates, Inc. If Mr. Moore holds or shares such power,
please advise why the 2,836,464 shares held b y the Clark Estates are not included in his
individual holdings (and in the holdings of all directors and officers as a group) in the
beneficial ownership table. Refer to Item 403 of Regulation S -K.
We urge all persons who are responsible for the accur acy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company
acknowledging that:
Abraham N. Reichental
3D Systems Corporation
June 15, 2012
Page 2
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; 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.
If you have any qu estions regarding our comment , please contact Matthew Crispino, Staff
Attorney, at (202) 551 -3456 or, in his absence, me at (202) 551 -3462 . Should you require further
assistance, you may contact Barbara C. Jacobs, Assistant Director, at (202) 551 -3735.
Sincerely,
/s/ Mark P. Shuman
Mark P. Shuman
Branch Chief - Legal