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    Robert M. Grace, Jr.

    Direct Dial: +1 803.326.3989

    Vice President, General Counsel

    And Secretary

June 11, 2010

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Stephen Krikorian

    Re:

    3D Systems Corporation

Form 10-K for the fiscal year ended December 31, 2009

File No. 001-34220

Gentlemen:

     On behalf of 3D Systems Corporation (the “Company”), I hereby respond to the comments of the
staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) to the above-referenced
filings set forth in its comment letter dated May 27, 2010 (the “Comment Letter”).

     In connection with its response, the Company acknowledges that:

    •

    It is responsible for the adequacy and accuracy of the disclosure in its
filings;

    •

    Staff comments or changes to disclosure in response to Staff comments do not
foreclose the SEC from taking any action with respect to the Company’s filings; and

    •

    the Company may not assert Staff comments as a defense in any proceeding
initiated by the SEC or any person under the federal securities laws of the United
States.

     For convenience of reference, I have set forth below the text of the comments in the Comment
Letter in bold, italicized text before the respective responses to each comment. In addition, I
have conformed the section headings and paragraph numbers to those in the Comment Letter.

3D
Systems Corporation • 333 Three D Systems Circle • Rock
Hill, SC 29730 • USA

Phone: 803.326.3900 • Fax: 803.326.4311 • www.3dsystems.com
• NASDAQ: TDSC

U.S. Securities and Exchange Commission

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June 11, 2010

FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2009

Consolidated Financial Statements

Note 6. Intangible Assets, page F-20

    1.

    Tell us your consideration of disclosing the weighted-average amortization period and
the estimated amortization expense over the next five years for the non-compete agreements.
We refer you to FASB ASC 350-30-50.

         In response to the Staff’s comment, the Company notes that, in preparing its Form 10-K
for the year ended December 31, 2009, the Company considered the need to break out the
components of Other Intangible assets. The Company concluded that none of the components of
Other Intangible assets, including the non-compete agreements, represented a major asset
class and that none of the future amortization amounts were material to the statement of
operations or to the balance sheet. Accordingly, the Company determined that disclosing the
amortization period and estimated amortization expense was not required. We have included
the table below, which breaks out the components of Other Intangible assets, to illustrate
the basis of our conclusions:

    Amounts in thousands

    Future Annual Amortization Expense

    12/31/09

    Net Balance

    2010

    2011-2014

    Internally developed software

    $
    0

    $
    0

    $
    0

    Other acquisition-related intangibles

    0

    0

    0

    Non-compete agreements

    151

    30

    30

    Trade names

    24

    24

    0

    Customer relationships

    551

    48

    48

    Backlog

    0

    0

    0

    Total

    $
    726

    $
    102

    $
    78

         In the event that the balance of any component of Other Intangible assets represents an
amount that, if broken out and disclosed separately, would be beneficial to users of the
Company’s financial statements in the future, the Company will then make the appropriate
disclosures as required by FASB ASC 350-30-50.

Note 14. Stock-Based Compensation and Stockholders’ Rights Plan, page F-24

    2.

    Tell us your consideration of providing all the disclosures required by FASB ASC
718-10-50 for the awards issued under your 2004 Stock Plan. As part of your response,

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June 11, 2010

    explain whether you estimate the fair value of the awards granted under the 2004 Stock Plan
using a valuation technique such as an option pricing model. We refer you to FASB ASC
718-10-30.

         In response to the Staff’s comment, the Company notes that as clarification to Note 14,
“Stock-Based Compensation and Stockholders’ Rights Plan” in its 2009 Form 10-K, the two
types of equity awards outstanding are restricted stock awards and stock options. Restricted
stock is valued based on the fair market value of the common stock at the close of business
on the date of grant less the amount paid by the recipient and is expensed over the vesting
period of each award. The only vesting requirement is the passage of time. As such, the use
of pricing models is not required for restricted stock awarded under the 2004 Stock Plan. In
regards to the stock options, all outstanding options under the Company’s plans were fully
vested prior to January 1, 2009. Accordingly, valuation techniques such as an option
pricing model were not needed as there was no expense associated with stock options in 2009.

Note 18. Computation of Net Income (Loss) per Share, page F-29

    3.

    You have not disclosed whether any potentially dilutive shares were excluded from the
calculation of diluted earnings per share as of December 31, 2009. Tell us how you
considered the awards issued under your 2004 Stock Plan and previous stock option plans
when determining the potentially dilutive shares to be included in diluted earnings per
share as of December 31, 2009. We refer you to the guidance in FASB ASC 260-10-10-2 and
FASB ASC 260-10-45-22 through 45-32.

         In response to the Staff’s comment, the Company notes that due to the positive net
income the Company reported in 2009, no dilutive potential common shares were excluded from
the diluted EPS calculation. As disclosed in the last paragraph of Note 18 to the Company’s
2009 Form 10-K, for 2008 and 2007, dilutive potential common shares were excluded due to the
Company’s loss position in those periods, the inclusion of which would have been
anti-dilutive.

         Stock options where the strike price was in excess of the market price at the close of
each period were appropriately not used in the diluted EPS calculation for all years
presented. These amounts were 354 thousand shares in 2009, 315 thousand shares in 2008, and
0 shares in 2007.

         In the future, the Company will add language to the disclosure to make it clear that
there were no dilutive potential common shares or state the amount of dilutive potential
common shares if there are any.

     Part III (Incorporated by reference from the Definitive Proxy Statement filed on March 31,
2010)

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June 11, 2010

Security Ownership of Certain Beneficial Owners and Management, page 7

    4.

    We note the statement in footnote 1 to the beneficial ownership table that the common
stock amounts provided in the table include, with respect to the stockholder in question,
common stock issuable upon exercise of vested options. We also note the statements
in several of the other footnotes that shares attributed to a particular stockholder
include shares of common stock covered by outstanding options that are currently
exercisable. Please confirm, and state in future filings, that the shares listed
in the table include shares the named persons or entities have a right to acquire within
sixty days. See Item 403 of Regulation S-K and Rule 13d-3(d)(1) under the Exchange Act.

         In response to the Staff’s comment, we confirm that the shares listed in the beneficial
ownership table on page 7 of the Company’s Proxy Statement filed on March 31, 2010 include
shares that the named persons or entities are deemed to own by virtue of Item 403 of
Regulation S-K and Rule 13d-3(d)(1) under the Exchange Act and therefore include all shares
that they have a right to acquire within sixty days.

         We are also pleased to confirm that the Company will continue to disclose in beneficial
ownership tables in future filings shares that the persons or entities listed are deemed to
own by virtue of Item 403 of Regulation S-K and Rule 13d-3(d)(1) under the Exchange Act and,
when appropriate, will state that such shares include shares the named persons or entities
have a right to acquire within sixty days.

Proposal One

Election of Directors, page 10

    5.

    We noted your statement in this section that your board “believes that each of the
nominees for director is well qualified to continue to serve as a director of the company.”
With a view toward providing enhanced disclosure in future filings, please identify for
each director nominee the particular experience, qualifications, attributes or skills that
led your board to conclude that the individual should serve as a director. Refer to Item
401(e)(1) of Regulation S-K and Question 116.05 of our Regulation S-K Compliance and
Disclosure Interpretations, available on our website.

         In response to the Staff’s comment, the Company set out on page 10 of the Proxy
Statement filed on March 31, 2010, in the expanded Business Experience disclosure of each
nominee for director set out on pages 11 and 12 of the Proxy Statement and in other
disclosures cross-referenced in the Proxy Statement lengthy disclosure of the experience,
qualifications, attributes or skills, and of the Board’s considerations, that led the
Company’s Board to conclude that the individuals nominated should serve as directors.

         With respect to Question 116.05 of the Staff’s Regulation S-K Compliance and Disclosure
Interpretations, we are pleased to confirm that the Company will provide

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June 11, 2010

    additional disclosure in future filings intended to amplify with respect to each
individual director nominee the particular experience, qualifications, attributes or skills
that led the Company’s Board to conclude that the individual should serve as a director.

Corporate Governance Matters

Board Leadership Structure, page 13

    6.

    You indicate in this section that you believe the separation of the positions of
Chairman and Chief Executive Officer has been beneficial to your company, although your
board does not view any particular board leadership structure as preferable. With a view
toward providing enhanced disclosure in future filings, please explain why you believe that
your current leadership structure is appropriate given your specific characteristics and/or
circumstances. Also, please discuss the extent of the board’s role in risk oversight and
the effect that this has on the board’s leadership structure. Refer to Item 407(h) of
Regulation S-K.

         In response to the Staff’s comment, the Company is pleased to confirm that the Board
separated the positions of Chairman and Chief Executive Officer in 1999, more than 10 years
ago as disclosed in the section entitled “Board Leadership Structure” on page 13 of the
Proxy Statement filed on March 31, 2010. Throughout that period, Mr. Loewenbaum, an
independent director, has occupied the position of Chairman.

         The Board determined that the existing leadership structure has proven to be beneficial
for the Company. We are pleased to confirm to you that, as a result of the Board’s informal
processes for communicating among members of the Board and evaluating the performance of
members of the Board, it has become clear to the Company that the Board is satisfied with
the current separation of the positions of Chairman and Chief Executive Officer, and the
Board has formally approved the incumbents in those positions. As a result of this ongoing
process, the Board did not deem it necessary to make any further formal determination as to
why this current leadership structure is appropriate.

         However, with a view toward providing enhanced disclosure in future filings, the
Company will recommend to the Board that it adopt enhanced procedures and processes for
determining whether its current leadership structure is appropriate given the Company’s
specific characteristics and/or circumstances and will disclose in future filings
information as to any related material conclusions of the Board.

         On the matter of risk management, we are pleased to confirm to you that the management
of risk is among the Board’s responsibilities in exercising its oversight responsibilities.
(Please see the section titled “Responsibility and Oversight” on page 13 of the Proxy
Statement for a discussion of the Board’s role in risk oversight.)

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June 11, 2010

         We can also advise you that 75% of the directors, including the Board’s Chairman, are
independent directors, all of the Company’s directors are mindful of and diligent in
carrying out their role in the oversight of the Company’s affairs, and all of them are fully
aware of their responsibility to exercise appropriate business judgment after considering
all relevant factors, including an evaluation of any related risks in matters that come
before them.

Related Party Transactions Policies and Procedures, page 17

    7.

    We note your disclosure in this section that in adopting your related party transaction
policy, your board preapproved certain types of transactions even if the amounts involved
exceed $120,000. We also note the statement in this section that “no transactions that
would constitute related-party transactions were considered by the Board or any of its
committees since the beginning of 2009.” Please clarify whether the company engaged in any
transactions since the beginning of fiscal 2009 that are required to be disclosed under
Item 404(a) of Regulation S-K.

         In response to the Staff’s comment, the Company is pleased to confirm that the Proxy
Statement dated March 31, 2010 does not disclose any transactions since the beginning of
fiscal 2009 that are required to be disclosed under Item 404(a) of Regulation S-K because
there were no such transactions.

Director Compensation for 2009, page 18

    8.

    The director compensation table indicates that Messrs. Curran and Kever were paid
$39,663 and $50,364, respectively, in fees for their services as directors during fiscal
2009. In light of the directors’ fees disclosed on page 19, however, it is unclear how
these two directors earned the amounts disclosed in the table. Please advise.

         In response to the Staff’s comment, the Company is pleased to advise the Staff that the
Company has reviewed the directors’ compensation set forth in the Proxy Statement filed on
March 31, 2010 and that the amounts of $39,663 and $50,364, respectively, for Messrs. Curran
and Kever in the table of directors’ compensation set forth on page 18 of the Proxy
Statement are accurate as is the summary of directors’ fees set forth on page 19 of the
Proxy Statement. We kindly direct your attention to the disclosure under “Audit Committee”
on page 14 of the Proxy Statement stating that “Mr. Curran became a member of the Audit
Committee on November 10, 2009 upon the retirement of Mr. Kever as a member of that
Committee.” The cash fees earned by each Board member during any year vary based on the
committees on which they serve and the meetings they attend. When a change is made during
the course of a year, any applicable cash fees are pro-rated.

    Employee Compensation and Attendant Risks, page 22

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June 11, 2010

    9.

    We note your statement in this section that you believe “there are no substantial risks
associated with our compensation practices and that any such risks that do exist are not
reasonably likely to result in a material adverse effect on us.” Please advise us of the
basis for this conclusion and describe the process you undertook to reach it.

         In response to the Staff’s comment, the Company is pleased to confirm that that it
unde