SEC Comment Letter for 3D SYSTEMS CORP (DDD) (CIK 0000910638) (DDD) — May 13, 2014
3D SYSTEMS CORP (DDD) (CIK 0000910638)
Date: May 13, 2014 · CIK: 0000910638 · Accession: 0000000000-14-024438
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May 13, 2014
Via E -mail
Abraham N. Reichental
Chief Executive Officer
3D Systems Corporation
333 Three D Systems Circle
Rock Hill, South Carolina 29730
Re: 3D Systems Corporation
Form 10-K for the Fis cal Year Ended December 31, 2013
Filed February 28, 2014
File No. 001 -34220
Dear Mr. Reichental :
We have reviewed your filing an d have the following comment. Please note that we have
limited our review to only your financial statements and related disclosures. In our comment , we
may ask you to provide us with information so we may better understand your disclosure.
Please respon d 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 this comment, we may have additional comments.
Item 7. Management’s Discu ssion and Analysis of Financial Condition and Results of
Operations
Summary of 2013 Financial Results, page 30
1. We note from your disclosure that you calculate organic growth by comparing last year’s
total revenue to this year’s total revenue, excluding t he revenue of all acquired businesses
that you have owned for less than twelve months. Please tell us whether your organic growth
includes any re -branded products from acquired businesses that you have owned for less than
twelve months. As part of your re sponse, please q uantify the amount of revenues from
businesses acquired in fiscal 2013 that are excluded from your calculation of organic growth
and tell us your consideration of disclosing the amount of revenues from acquired businesses
for each period pr esented.
Abraham N. Reichental
3D Systems Corporation
May 13, 2014
Page 2
We urge all persons who are responsible for the accuracy 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 comment, please provide a written statement from the company
acknowledging that:
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 wi th 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.
You may contact Morgan Youngwood, Staff Accountant, at (202) 551-3479 or Christine
Davis, Assistant Chief Accountant, at (202) 551 -3408, if you have any questions regarding
comments on the financial statements and related matters . Please contact me at (202) 551 -3730
with any other questions.
Sincerely,
/s/ Stephen Krikorian
Stephen Krikorian
Accounting Branch Chief