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3D Systems Corporation

Via UPS

    U.S. Securities and Exchange Commission

Mail Stop 4561

450 Fifth Street, N.W.

Washington, D.C. 20546-0406

    Attn:

    Mr. Stephen Krikorian/Accounting Branch Chief

Mr. Chris White/Sr. Staff Accountant

May 2, 2008

    Re:

    3D Systems Corporation

Form 10-K/A for the Fiscal Year Ended December 31, 2006

Form 10-Q for the Quarterly Period Ended September 30, 2007

File No. 000-22250

Dear Mr. Krikorian and Mr. White:

     On behalf of 3D Systems Corporation, a Delaware corporation (the “Company”), and in connection
with Form 10-K/A for the Fiscal Year Ended December 31, 2006, (the “Form 10-K/A”) and the Form 10-Q
for the Quarterly Period ended September 30, 2007, we hereby respectfully respond to the March 4,
2008, comment letter of the Staff of the Securities and Exchange Commission. The paragraph
numbering and headings of this letter correspond to the paragraph numbering used in the Staff’s
March 4th letter. Unless otherwise indicated, page references herein refer to the pages
of the Form 10-K/A. For convenience of reference, we have included the text of the Staff’s comments
in bold text preceding the respective responses.

Securities and Exchange Commission

May 2, 2008

Page 2 of 17

Form 10-K/A for the Fiscal Year Ended December 31, 2006

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

    1.

    We note your response to comment 2 of our letter dated February 7, 2008 and we
reissue the comment. We are unable to reconcile the proposed response with the disclosure
requirements of Item 303 of Regulation S-K. It appears that a significant impact on
revenues resulted from a change in prices that you do not quantify. Further, it appears
that the changes in average prices of products delivered is a trend that has affected your
results historically and which may affect those results in future periods. As previously
requested, please quantify the amount of the change in prices and provide appropriate
quantitative or qualitative disclosure of the impact on the change in prices. In addition,
with respect to a change in the “product mix”, although you state that there has been a
trend toward lower-price systems that significantly affected revenue and operating
results, we are currently unable to concur that quantitative and additional qualitative
disclosure is not required.

     We note that the Staff has reissued its original comment 2 requesting a more detailed
explanation of price and mix effects. With respect to your reference to the requirements of Item
303 of Regulation S-K, we kindly call your attention to our February 7, 2008 response letter in
which we stated that:

    “We are aware of the MD&A requirements that encourage the disclosure of quantitative
information relating to, among other things, factors that affect changes in revenue, and
have provided that information to the extent that it was practicable to do so without undue
effort and expense.”

     As indicated in the Form 10-K/A for the year ended December 31, 2006 and further described in
our response letter, our reporting systems were not configured to produce more detailed
quantitative information on price and mix effects for the period in question.

     Our response letter evidenced our intention to consider further disclosure on price and mix
effects in future filings. We stated that:

    “We are pleased to advise you that, at such time as we are able to produce more detailed
quantitative data with respect to the effect of price and mix changes as they affect
revenue that would be meaningful and material to investors, we intend to do so in future
filings.”

Securities and Exchange Commission

May 2, 2008

Page 3 of 17

     In light of the Staff’s reassertion of its comment 2, in preparing our Annual Report on Form
10-K for the year ended December 31, 2007, which we filed with the SEC on March 17, 2008 (the “2007
Form 10-K”), we considered this intention and supplemented our prior disclosures of price and mix
effects by stating, as set forth in the MD&A on page 28 of the 2007 Form 10-K, that:

    “Our reporting systems are not currently configured to produce more quantitative
information regarding the effect of price and mix changes on revenue.”

     As such, we are currently not able to further quantify the amount of the change in prices or
product mix or to provide further quantitative disclosure of the impact of the change in prices or
product mix on revenue for any past periods.

     We also considered the Staff’s comments in its letter dated March 4, 2008 that “it appears
that a significant impact on revenues resulted from a change in prices that [we] do not quantify”
and that “changes in average prices of products delivered is a trend that has affected [our]
results historically and which may affect those results in future periods.” We believe that
disclosures to that effect would not be accurate in the context of our performance and for that
reason would be inappropriate for us to make. We did, however, conclude that we had a reasonable
basis for making the disclosure set forth below, which the Staff will also see in the MD&A
disclosure on page 28 of the 2007 Form 10-K:

    “However, we believe that changes in product mix, rather than changes in average
selling prices, are the principal contributor to the price and mix effects that we
experienced in 2007, 2006 and 2005.”

     As we have previously advised the Staff, at such time as we are able to produce more detailed
quantitative data with respect to the effect of price and mix changes as they affect revenue that
would be meaningful and material to investors, we intend to do so in future filings.

Securities and Exchange Commission

May 2, 2008

Page 4 of 17

Notes to Consolidated Financial Statements

Note 2 Significant Accounting Policies

Revenue Recognition, page F-11

    2.

    We note you have concluded that software is incidental to your product as a whole in
response to prior comment number 3. Your response states that your maintenance contracts
do not provide for software upgrades in support of your conclusion. Please clarify how you
evaluated the software downloads available on your website for SLA and SLS systems when
determining that you do not offer software upgrades. In this respect, we note that you
“provide the latest available software modules for download” for customers “currently on
warranty or those with a current 3D Systems maintenance plan.” Explain whether the
software upgrades offered to your customers on your website relates to the software
embedded in your SLA and SLS systems. If so, further clarify how you determined that your
maintenance contracts do not provide for software upgrades and how you determined that the
software in your systems are incidental to the product as a whole.

     Our website does not employ the word “upgrade” with respect to its meaning in terms of
accounting revenue recognition.

     Generally, the upgrades offered to our customers on our website are updates related to the
software embedded in our SLA® and SLS® machines. The software works with only our machines and our
machines work with only our software. More specifically, we define updates and upgrades as follows:

    •

    Software updates are generally related to patches, programming corrections, or
minor enhancements to our software and are included as part of our warranty and
maintenance plans.

    •

    Software upgrades provide new functionality as a new software package and are
generally sold separately.

     The updates available to our customers under warranty and maintenance plans relate to software
embedded in our machines. These plans are optional and are not essential to the functionality of
the software. More specifically, we define warranty and maintenance as follows:

    •

    A warranty is our agreement with a machine purchaser that we will, without charge,
repair or replace defects in the machine within a given time limit and under certain
conditions. Warranty coverage is generally for a three month period. After which,
extended warranties for up to one year of coverage are available at the time of
purchase. Warranty and extended warranty revenue is a deferred portion of the machine
revenue. The vendor specific objective evidence of fair value is deferred and
recognized over the respective term. As discussed in comment 3.

Securities and Exchange Commission

May 2, 2008

Page 5 of 17

    •

    Our maintenance plans are agreements to perform certain agreed upon services to
maintain a product for a specified period of time beyond the period covered by the
original warranty periods discussed above. Customers desiring maintenance have to sign
new agreements at prices based on the then current price list. Customers are not
required to remain on maintenance. Maintenance revenue is deferred and recognized
ratably over the term.

     The software downloads from our website for customers currently on warranty or on a
maintenance plan are for software updates generally related to patches, programming corrections, or
minor enhancements. These downloads typically do not represent substantial changes in
functionality. Furthermore, updates are not required for the machine to function as originally
sold. Customers are not required to purchase maintenance or extended warranty plans.

     Software upgrades may be purchased separately by our customers, at their discretion, as they
are not part of a warranty or maintenance plan. Generally, when substantive changes in
functionality are made to our software, a new software package is created, and our customers may
purchase it separately as this upgrade is not offered under our warranty or maintenance plans. We
specifically address this in the service agreements with our customers as we reserve the right to
define a new software package when new functionality is added to our software. Upgrades and updates
are not required for the machine to operate as originally sold.

     In the unusual instances when updates are more than minor increases in functionality, such
updates are offered at no additional cost to all customers covered under a related active warranty
or maintenance plan. These updates are not required to operate the system as originally sold.
Customers who have elected not to purchase extended warranty or maintenance plans still have use of
the product As discussed in response below to the Staff’s Comment 3, the revenue from warranty and
maintenance plans is recognized ratably over the term of the agreement.

     The software licensed, including any separately purchased upgrades, is integral to the
operation of our machines. However, it will not function without our machines as the software is
embedded into the machine. It is incidental to the product as a whole.

     Though our machines have a software component, SOP 97-2 was deemed not applicable. Our
conclusion was based on the following analysis:

    •

    Our software is critical, as in SOP 97-2 Example 1 below, to the operation of our
machine, but it is neither the focus of our marketing efforts nor is it what the
customer perceives he or she is obtaining. Our costs incurred for the development of
the software are within the scope of FASB Statement No. 86, Accounting for the Costs
of Computer Software to Be Sold, Leased, or

Securities and Exchange Commission

May 2, 2008

Page 6 of 17

    Otherwise Marketed, and the production costs of such software are insignificant
relative to the other development and production costs of the system;

    •

    Our software is not, as in SOP 97-2 Example 2 below, the focus of our marketing
efforts. Our software is not prominently displayed in our marketing literature,
convention kiosks, or web site. Our machines are the focus of our marketing efforts;
and

    •

    Our software is not, as in SOP 97-2 Example 3 below, valued by the customer without
the machine.

    •

    Though we offer maintenance and extended warranty plans which include updates to
our software, these plans are not essential to the software nor are they required to
be purchased. Additionally, the updates that are available with these plans are not
needed for the machine to operate as sold.

Additional indicators that we considered when determining that our software was incidental to the
product as a whole were:

    •

    Our software can neither be used on competitor products nor can it be downloaded
from one of our machines and to another of one of our machines

    •

    Our software does not require our customers to provide dedicated information
technology support;

    •

    Our software may not be substituted for software provided by a competitor as our
machines work with only our software; and

    •

    Our product is not sold or distributed along with other software products.

     We therefore concluded that the software component is incidental to the system as a whole.
Accordingly we concluded that EITF 03-5, Applicability of AICPA Statement of Position 97-2 to
Non-Software Deliverables in an Arrangement Containing More-Than-Incidental Software, does not
apply to our machines and our incidental software.

     The following examples referred to above are excerpts from Appendix A of SOP 97-2 —
Paragraph .146:

    Example 1

    Facts

An automobile manufacturer installs software into an automobile model. This
software is used solely in connection with operating the automobile and is not sold
or marketed separately. Once installed, the software is not updated for new
versions that the manufacturer subsequently develops. The automobile manufacturer’s
costs for the development of the software that are within the scope of FASB
Statement No. 86, Accounting for the Costs of Computer Software to Be Sold, Leased,
or Otherwise Marketed

Securities and Exchange Commission

May 2, 2008

Page 7 of 17

    and the production costs of such software are insignificant relative to the other
development and production costs of the automobile.

    Applicability

The Statement of Position (SOP) is not applicable to such software because the
software is deemed incidental to the product as a whole.

    Discussion

Although the software may be critical to the operations of the automobile, the
software itself is not the focus of the marketing effort, nor is it what the
customer perceives he or she is obtaining. The development and production costs of
the software as a component of the cost of the automobile is incidental.

    Example 2

    An entity develops interactive training courses for sale or licensing to customers.
These courses are delivered on a compact disc, which is loaded onto a customer’s
computer. The courses are developed such that, based on the responses received to a
particular question, different questions are generated and content of the course
material that is displayed is determined in a manner that directs the user’s
learning experience in a more focused way. The course developer’s costs for the
development of the software content are within the scope of Subtopic 985-20 and are
significant. The interactive nature of the courses is mentioned prominently in the
marketing efforts.

    Discussion

The software revenue recognition literature is applicable because the software is
not incidental to the product. Although some might argue that the product is maps,
not software, the marketing of the product focuses on the interactive features made
possible by the software. In this situation, the conclusion would not change, even
if the software development costs were small and no post-sale upgrade or technical
support were provided.

    Example 3

    Company A manufactures a handheld personal organizer that includes a calendar,
address book, calculator, and game modules. The personal organizer operates using a
proprietary software operating system, for which upgrades are periodically