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Correspondence

3D Systems Corporation has requested confidential treatment pursuant to 17 C.F.R §200.83. This letter omits confidential information (denoted by asterisks) and an unredacted
version of this letter has been delivered to the U.S. Securities and Exchange Commission Division of Corporate Finance.

 ANDREW M. JOHNSON

 VICE PRESIDENT, GENERAL COUNSEL

AND SECRETARY

DIRECT DIAL: +1 803.326.4003

 April 26, 2013

 Via EDGAR

 U.S. Securities and Exchange Commission

Division of Corporation Finance

 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, 2012

 Filed February 25, 2013

 Form 8-K

Filed on February 25, 2013

 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 April 4, 2013 (the “Comment Letter”).

Please note that the Company is requesting confidential treatment pursuant to Rule 83 of the Commission’s Rules on Information
Requests, 17 C.F.R. §200.83, with respect to portions of the responses to Comments 1 and 7. Such information is being provided to the Commission in its entirety in hard copy under separate cover along with the request for confidential
treatment. Please note that the version of this letter submitted via EDGAR omits confidential information included in the unredacted version delivered to the Staff, and the redactions are denoted in the EDGAR version by bracketed asterisks
(“[***]”). In the event that the Staff receives a request for access to the confidential portions herein, whether pursuant to the Freedom of Information

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Act or otherwise, we respectfully request that we be notified immediately. Please address any notification of a request for access to such information to the undersigned at the address shown
above, via telephone at (803) 326-4003, or via fax at (803) 326-4796.

 In connection with its response, the Company
acknowledges that:

•

 It 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 SEC 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 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 each comment in the Comment
Letter in bold, italicized text before the response to the comment. In addition, I have conformed the section heading and paragraph numbers to those in the Comment Letter.

 Form 10-K for the Fiscal Year Ended December 31, 2012

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

Summary of 2012 Financial Results, page 30

1.
In your response letter, please provide a table disclosing quarterly revenue from the date of acquisition for each acquisition you completed in fiscal
2012.

 The following table discloses quarterly revenue from the date of acquisition for
each acquisition we completed in 2012:

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 Rule 83 confidential treatment request made
by 3D Systems Corporation; Request Number 1.

(in thousands)

 2012 Acquisitions

Q1 2012

Q2 2012

Q3 2012

Q4 2012

Total 2012

 Z Corporation / Vidar Systems

[*****
]

[*****
]

[*****
]

[*****
]

[*****
]

 Fresh Fiber B.V

—

[*****
]

[*****
]

[*****
]

—

 Kodama Studios (My Robot Nation)

—

[*****
]

[*****
]

[*****
]

—

 Paramount Industries

—

[*****
]

[*****
]

[*****
]

—

 Bespoke Innovations

—

[*****
]

—

[*****
]

—

 Viztu Technologies

—

—

—

—

—

 TIM The Innovative Modelmakers B.V.

—

—

—

—

—

 INUS Technologies (Rapidform)

—

—

—

[*****
]

—

 Total revenue from 2012 acquisitions

[*****
]

[*****
]

[*****
]

[*****
]

[*****
]

 Total 3D Systems reported revenue

$
77,920

$
83,610

$
90,532

$
101,571

$
353,633

 Revenue and operating income for Z Corporation and Vidar Systems was included in our Form
10-K for the year ended December 31, 2012. Z Corp and Vidar were the only material acquisitions we completed during 2012. The remainder of the acquisitions were not material individually or in the aggregate.

Liquidity and Capital Resources, page 42

2.
Tell us your consideration of providing liquidity disclosures to discuss the potential tax impact associated with the repatriation of
undistributed earnings of foreign subsidiaries. In this regard, consider disclosing the amount of cash and investments that are currently held by your foreign subsidiaries and disclose the impact of repatriating the undistributed earnings of foreign
subsidiaries. We refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350.

 We considered Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350. However, as noted in our response to Comment 10, the undistributed earnings are permanently invested and it is
not practicable to estimate the deferred taxes associated with any undistributed earnings. We considered this fact, as well that disclosing any tax impact associated with cash balances held by foreign subsidiaries would involve:

•

 Determining the amount of cash potentially available for distribution;

•

 Determining the amount of income subject to tax, which would not be equal to the cash balances; and

•

 The factors listed with Comment 10.

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 We consider the cash to be permanently
invested. The cash invested overseas is not needed for domestic operations and we intend to use it in our non-U.S. operations, and to fund overseas acquisitions and expansions. Given that we consider the cash to be permanently invested and given the
complexities in estimating deferred taxes associated with any undistributed earnings, we, after careful consideration, concluded that it was impracticable to determine the tax liability, if any, associated with the foreign cash balances.

In response to the Staff’s comment, we will continue to evaluate our disclosure in connection with future filings
regarding the amount of cash and investments in foreign subsidiaries in accordance with such comment and, where material, we will provide additional disclosure as appropriate.

 Consolidated Financial Statements

 Note 2. Summary of Significant
Accounting Policies

 Revenue Recognition, page F-8

3.
We note from your disclosures that you recognize revenue on sales to resellers at the time of sale when the reseller has economic substance apart from
company and you have completed your obligations related to the sale. Explain in greater detail how you recognize revenue generated through resellers and distributors. If revenue is recognized based on a sell-through model, tell us how you confirm
that an end-user has purchased your product and the product has been delivered. Describe the type of evidence obtained from the reseller and the timeliness of this evidence. In addition, indicate whether there are any rights of return held by the
reseller or end-user. If so, tell us how your accounting complies with ASC 605-15-25-1 and 3.

 Pursuant to ASC 605-15-25-1 and 3, we recognize revenue when persuasive evidence of a sales arrangement exists, delivery has occurred or services are rendered, the sales price or fee is fixed or
determinable and collectability is reasonably assured.

 We sell products through our direct sales force and
through authorized resellers. We enter into agreements with resellers that allow them to purchase our products at a discount. Our resellers have economic substance apart from Company. In the course of qualifying the reseller, we perform an
authorization process, which includes reviewing the potential reseller’s payment history and credit agency rating, to determine the amount of credit, if any, that should be extended. We recognize revenue on sales to resellers at the time of
sale when both title and risk of loss have passed to the reseller, and we have completed our obligations related to the sale.

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 We believe our processes result in
cultivating resellers who have the financial wherewithal to conduct transactions with us that are at arm’s length. We do not operate based on a “sell through” model, and our resellers generally do not purchase printers for their
inventory. Our terms and conditions do not offer our resellers the right to return a product, and they are not conditional upon the ultimate sale to the end user by the reseller.

In certain situations, the reseller receives a commission for facilitating a transaction between us and the customer. At
the time of shipment, title passes to the customer and revenue, as well as the related commission expense, is recognized.

4.
Your disclosures indicated that you market and sell software tools that enable your customers to capture and customize content using your printers as well
as reverse engineering and inspection software. Please clarify your disclosures that indicate the software is sold separately and is not part of a multiple-element arrangement. Please indicate whether customers also purchase post sale support (i.e.,
PCS). Describe the methodology and assumptions you use to establish VSOE of fair value for PCS in these arrangements. Further, tell us how you establish VSOE for software if customers also acquire PCS.

We continually review our disclosures and our revenue recognition policies were updated to include ASC 985-605,
Software-Based Revenue Recognition, on page F-9. Our current disclosure includes the following statement in the first paragraph under the heading Software:

 “In general, this software is sold separately and is not part of a multiple element arrangement.”

 We did not intend to give the impression that all of the software was sold separately and was not part of a multiple element arrangement but that it is normally sold separately and normally is not part of
a multiple element arrangement. Because there are instances when customers purchase PCS, we stated the following in the last sentence of the same paragraph:

 “Post sale support is considered a separate element from the software and is deferred at the time of sale and subsequently amortized in future periods.”

We will update the disclosure in future filings by changing the preceding statement as follows:

“In instances in which customers purchase post sale support, it is considered a separate element from the software and is deferred
at the time of sale and subsequently amortized in future periods.”

 Pursuant to ASC 985-605,
Software-Based Revenue Recognition, we allocate the total fee arrangement to the software and the PCS undelivered elements based on vendor

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specific objective evidence (“VSOE”). Our customers may purchase our software with or without PCS. We allocate the total fee arrangement based on the guidance set forth in ASC
985-605-25-67, which states that the fair value of the PCS should be determined by reference to the price the customer will be required to pay for the PCS when it is sold separately. We establish VSOE of PCS based upon the stated renewal method,
which generally occurs a year after the software is purchased. As a matter of policy, stated renewal rates are included in the form of an optional renewal rate provided to the customer. The portion of the fee allocated to the PCS is recognized as
revenue ratably over the term of the PCS arrangement.

5.
Please clarify your reference that hardware “deliverable is recognized ratably based on relative fair values of the components of the sale.” In
this regard, clarify whether hardware revenue is recognized ratably (i.e., over an attribution period) or upon delivery. In addition, describe your evaluation of ASC 985-605-15-14A as it applies to your hardware and software sales.

 Hardware

 In general, revenues are separated between printers and other products, print materials, training services, maintenance services and installation services. The software embedded in the printers is
incidental to the equipment as a whole such that ASC 985 is not applicable. Sales of these products are recognized in accordance with ASC 605-25, “Multiple-Element Arrangements.” The allocated revenue for each deliverable is then
recognized based on relative fair values of the components of the sale, consistent within the scope of Financial Accounting Standards Board ASC 605 Revenue Recognition.

Under our standard terms and conditions of sale, title and risk of loss transfer to the customer at the time the product
is shipped to the customer and revenue from the delivered product is recognized accordingly, unless customer acceptance is uncertain or significant obligations remain. The Company defers the estimated cost of post-sale obligations, including basic
product warranties, at the time it recognizes revenue. Post-contract customer support revenue that includes warranty and maintenance is recognized ratably over the term of the stipulated time period.

Software

 We also market and sell software tools that enable our customers to capture and customize content using our printers, as well as reverse engineering and inspection software. Our software is sold
separately, with or without post-contract customer support, or as part of a multiple-element arrangement that includes hardware.

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 The software does not require significant
modification or customization. We apply the guidance in ASC 985-605, Software-Revenue Recognition in recognizing revenue when software is more than incidental to the product or service as a whole.

We sell equipment with embedded software to our customers. The embedded software is not sold separately, it is not a
significant focus of the marketing effort and we do not provide post-contract customer support specific to the software or incur significant costs that are within the scope of ASC 985. Additionally, the functionality that the software provides is
marketed as part of the overall product. The software embedded in the equipment is incidental to the equipment as a whole such that ASC 985 is not applicable. Sales of these products are recognized in accordance with ASC 605.25,
“Multiple-Element Arrangements.”

 Services

We provide end-users with maintenance under a warranty agreement for up to one year and defer a portion of the revenue
from the related printer sale at the time of sale based on the relative fair value of those services. After the initial warranty period, we offer these customers optional maintenance contracts. Deferred maintenance revenue is recognized ratably, on
a straight-line basis, over the period of the contract, and we recognize the costs associated with these contracts as incurred. Revenue from training, installation and non-contract maintenance services is recognized at the time of performance.

 Our software warranty or maintenance is recognized as service revenue.

On-demand printed parts sales are included within services revenue and revenue is recognized upon shipment or delive