SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Company Response from 3D SYSTEMS CORP (DDD) (CIK 0000910638) (DDD) — Jun 4, 2013

3D SYSTEMS CORP (DDD) (CIK 0000910638)
Date: June 4, 2013 · CIK: 0000910638 · Accession: 0001193125-13-247200

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-34220

Referenced dates: April 26, 2013, April 4, 2013

Date
June 4, 2013
Author
/s/ Andrew M. Johnson
Form
CORRESP
Company
3D SYSTEMS CORP (DDD) (CIK 0000910638)

Letter

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

June 4, 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:

In a letter dated April 26, 2013, on behalf of 3D Systems Corporation (the “Company”), I responded 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”). On behalf of the Company, I hereby provide additional information responsive to the request made by Mr. Matthew Crispino in a follow up telephone conversation on May 30, 2013.

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 response. 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

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

Phone: 803.326.3900 • www.3dsystems.com • NYSE: DDD

U.S. Securities and Exchange Commission

Page

June 4, 2013

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 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.

For convenience of reference, I have set forth below Mr. Crispino’s request for additional information in bold, italicized text before the response.

[Remainder of page intentionally left blank.]

CONFIDENTIAL TREATMENT REQUESTED BY 3D SYSTEMS CORPORATION

3D SYSTEMS 06042013-2

U.S. Securities and Exchange Commission

Page

June 4, 2013

For each of the Company’s twelve acquisitions during 2011, please provide a table disclosing the 2012 revenue that was considered acquired revenue.

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

Revenue from acquisitions (in thousands)

Q1 2012

Q2 2012

Q3 2012

Q4 2012

2012 Total

Acq Date

2012 acquisitions

Jan-12

Z Corporation

[******]

[******]

[******]

[******]

[******]

Jan-12

Vidar Systems Corporation

[******]

[******]

[******]

[******]

[******]

Apr-12

Fresh Fiber B.V

[******]

[******]

[******]

[******]

[******]

Apr-12

Kodama Studios (My Robot Nation)

[******]

[******]

[******]

[******]

[******]

Apr-12

Paramount Industries

[******]

[******]

[******]

[******]

[******]

May-12

Bespoke Innovations

[******]

[******]

[******]

[******]

[******]

Jul-12

Viztu Technologies

[******]

[******]

[******]

[******]

[******]

Oct-12

TIM The Innovative Modelmakers B.V.

[******]

[******]

[******]

[******]

[******]

Oct-12

INUS Technologies (Rapidform)

[******]

[******]

[******]

[******]

[******]

Revenue from 2012 acquisitions

[******]

[******]

[******]

[******]

[******]

Acq Date

2011 acquisitions

[******]

[******]

[******]

[******]

[******]

Jan-11

National RP Support

[******]

[******]

[******]

[******]

[******]

Feb-12

Quickparts

[******]

[******]

[******]

[******]

[******]

Mar-11

Accelerated Technologies (ATI)

[******]

[******]

[******]

[******]

[******]

Apr-11

Print 3D Corporation

[******]

[******]

[******]

[******]

[******]

Apr-11

Sycode

[******]

[******]

[******]

[******]

[******]

May-11

The 3dStudio.com

[******]

[******]

[******]

[******]

[******]

May-11

Freedom of Creation

[******]

[******]

[******]

[******]

[******]

Jul-11

Alibre Inc

[******]

[******]

[******]

[******]

[******]

Aug-11

Content Media (Botmill)

[******]

[******]

[******]

[******]

[******]

Sep-11

Formero Pty

[******]

[******]

[******]

[******]

[******]

Oct-11

Kemo Modelmakerij

[******]

[******]

[******]

[******]

[******]

Nov-11

Huntsman (Renshape & Digitalis)

[******]

[******]

[******]

[******]

[******]

Revenue from 2011 acquisitions

[******]

[******]

[******]

[******]

[******]

Adjustments*

[******]

[******]

[******]

[******]

[******]

Total acquired revenue in 2012

[******]

[******]

[******]

[******]

[******]

Total 2012 Revenue

$ 77,920

$ 83,610

$ 90,532

$ 101,571

$ 353,633

Less 2012 Acquired Revenue

[******]

[******]

[******]

[******]

[******]

Total 2012 Organic Revenue

[******]

[******]

[******]

[******]

[******]

Less 2011 Revenue

(47,896 )

(55,128 )

(57,538 )

(69,861 )

(230,423 )

[B]

2012 Organic Revenue Increase

[******]

[******]

[******]

[******]

[******]

[A]

Organic Growth

26.1 %

19.9 %

26.2 %

18.8 %

22.4 %

[A/B]

*[******]

CONFIDENTIAL TREATMENT REQUESTED BY 3D SYSTEMS CORPORATION

3D SYSTEMS 06042013-3

U.S. Securities and Exchange Commission

Page

June 4, 2013

* * * * * *

We deeply appreciate the Staff’s availability by phone to further assist the company and trust that the foregoing adequately responds to the comments.

Please do not hesitate to contact me at (803) 326-4003 if you have any questions regarding our responses. We would welcome the opportunity to discuss this matter if not addressed to your satisfaction above with appropriate persons on the Staff with the objective of resolving any remaining open concerns of the Staff.

Very truly yours,
/s/ Andrew M. Johnson

Show Raw Text
CORRESP
1
filename1.htm

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

 June 4, 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:

 In a letter dated
April 26, 2013, on behalf of 3D Systems Corporation (the “Company”), I responded 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”). On behalf of the Company, I hereby provide additional information responsive to the request made by Mr. Matthew Crispino
in a follow up telephone conversation on May 30, 2013.

 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 response. 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

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

 Phone: 803.326.3900   •   www.3dsystems.com   •   NYSE: DDD

 U.S. Securities and Exchange Commission

  Page
 2

 June 4, 2013

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
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.

 For convenience of reference, I have set forth below Mr. Crispino’s request for additional
information in bold, italicized text before the response.

 [Remainder of page intentionally left blank.]

 CONFIDENTIAL
TREATMENT REQUESTED BY 3D SYSTEMS CORPORATION

 3D SYSTEMS 06042013-2

 U.S. Securities and Exchange Commission

  Page
 3

 June 4, 2013

 For each of the Company’s twelve acquisitions during 2011, please provide a
table disclosing the 2012 revenue that was considered acquired revenue.

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

Revenue from acquisitions (in thousands)

Q1 2012

Q2 2012

Q3 2012

Q4 2012

2012 Total

 Acq Date

2012 acquisitions

 Jan-12

 Z Corporation

[******]

[******]

[******]

[******]

[******]

 Jan-12

 Vidar Systems Corporation

[******]

[******]

[******]

[******]

[******]

 Apr-12

 Fresh Fiber B.V

[******]

[******]

[******]

[******]

[******]

 Apr-12

 Kodama Studios (My Robot Nation)

[******]

[******]

[******]

[******]

[******]

 Apr-12

 Paramount Industries

[******]

[******]

[******]

[******]

[******]

 May-12

 Bespoke Innovations

[******]

[******]

[******]

[******]

[******]

 Jul-12

 Viztu Technologies

[******]

[******]

[******]

[******]

[******]

 Oct-12

 TIM The Innovative Modelmakers B.V.

[******]

[******]

[******]

[******]

[******]

 Oct-12

 INUS Technologies (Rapidform)

[******]

[******]

[******]

[******]

[******]

 Revenue from 2012 acquisitions

[******]

[******]

[******]

[******]

[******]

 Acq Date

 2011 acquisitions

[******]

[******]

[******]

[******]

[******]

 Jan-11

 National RP Support

[******]

[******]

[******]

[******]

[******]

 Feb-12

 Quickparts

[******]

[******]

[******]

[******]

[******]

 Mar-11

 Accelerated Technologies (ATI)

[******]

[******]

[******]

[******]

[******]

 Apr-11

 Print 3D Corporation

[******]

[******]

[******]

[******]

[******]

 Apr-11

 Sycode

[******]

[******]

[******]

[******]

[******]

 May-11

 The 3dStudio.com

[******]

[******]

[******]

[******]

[******]

 May-11

 Freedom of Creation

[******]

[******]

[******]

[******]

[******]

 Jul-11

 Alibre Inc

[******]

[******]

[******]

[******]

[******]

 Aug-11

 Content Media (Botmill)

[******]

[******]

[******]

[******]

[******]

 Sep-11

 Formero Pty

[******]

[******]

[******]

[******]

[******]

 Oct-11

 Kemo Modelmakerij

[******]

[******]

[******]

[******]

[******]

 Nov-11

 Huntsman (Renshape & Digitalis)

[******]

[******]

[******]

[******]

[******]

 Revenue from 2011 acquisitions

[******]

[******]

[******]

[******]

[******]

 Adjustments*

[******]

[******]

[******]

[******]

[******]

 Total acquired revenue in 2012

[******]

[******]

[******]

[******]

[******]

 Total 2012 Revenue

$
77,920

$
83,610

$
90,532

$
101,571

$
353,633

 Less 2012 Acquired Revenue

[******]

[******]

[******]

[******]

[******]

 Total 2012 Organic Revenue

[******]

[******]

[******]

[******]

[******]

 Less 2011 Revenue

(47,896
)

(55,128
)

(57,538
)

(69,861
)

(230,423
)

[B]

 2012 Organic Revenue Increase

[******]

[******]

[******]

[******]

[******]

[A]

 Organic Growth

26.1
%

19.9
%

26.2
%

18.8
%

22.4
%

[A/B]

*[******]

 CONFIDENTIAL
TREATMENT REQUESTED BY 3D SYSTEMS CORPORATION

 3D SYSTEMS 06042013-3

 U.S. Securities and Exchange Commission

  Page
 4

 June 4, 2013

 * * * * * *

 We deeply appreciate the Staff’s availability by phone to further assist the company and trust that the foregoing adequately responds to the comments.

Please do not hesitate to contact me at (803) 326-4003 if you have any questions regarding our responses. We would welcome the
opportunity to discuss this matter if not addressed to your satisfaction above with appropriate persons on the Staff with the objective of resolving any remaining open concerns of the Staff.

Very truly yours,

 /s/ Andrew M. Johnson

Andrew M. Johnson

Vice President, General Counsel and Secretary

cc:
Abraham N. Reichental

 Damon J.
Gregoire

 CONFIDENTIAL
TREATMENT REQUESTED BY 3D SYSTEMS CORPORATION

 3D SYSTEMS 06042013-4