United States securities and exchange commission logo December 21, 2023 Emmet Pepe Chief Financial Officer GSE SYSTEMS INC 6940 Columbia Gateway Drive, Suite 470 Columbia, MD 21046 Re: GSE SYSTEMS INC Registration Statement on Form S-3 Filed December 19, 2023 File No. 333-276128 Dear Emmet Pepe: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Austin Pattan at 202-551-6756 with any questions. Sincerely, Division of Corporation Finance Office of Technology cc: Scott Wilson