SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

    Mail Stop 6010
May 19, 2008

 Mr. Joseph D’Agostino Chief Financial Officer Milestone Scientific, Inc. 220 South Orange Avenue Livingston Corporate Park Livingston, NJ 07039   RE: Milestone Scientific, Inc.
  Form 10-KSB for the fiscal year ended December 31, 2007   Filed March 31, 2008   Form 10-Q for the period ended March 31, 2008
Filed May 15, 2008 File No. 1-14053
 Dear Mr. D’Agostino:
We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in future filings in response to these comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Joseph D’Agostino
Milestone Scientific, Inc.
May 19, 2008 Page 2   Form 10-KSB for the Fiscal Year ended December 31, 2007

Management’s Discussion and Analysis, page 16

Liquidity and Capital Resources, page 23

1. Please revise future filings to discuss significant changes to the components of
working capital – i.e., individually significant changes in line items.  For example,
we note accounts payable increased signifi cantly over the past year.  Please
address the impact on your working capital.  We note that we issued this same comment in a Staff’s comment lette r dated October 12, 2007, to which you
responded in your response letter dated November 15, 2007 that you would make this disclosure in your next Form 10- KSB.  We fail to see the disclosure.
 Statements of Operations, page F-5

2. We refer to the loss on disposal of equipment of $241,530 in the year ended
December 31, 2007.  We generally believe that gains and losses resulting from
write-down or sale of assets previously us ed in operations should be classified as
operating items in the income statement.  This treatment appears consistent with
the guidance prescribed by SFAS 144, as we ll.  Accordingly, in future filings
please classify these items in the operating section of the income statement or tell
us why you consider the presen t classification appropriate.

3. To this regard, please tell us your cons ideration given to the guidance at
paragraphs 41 – 44 of SFAS 144 in re porting the disposition of your teeth
whitening business.  Clarify your future disclosures as nece ssary based on our
concerns.

Exhibit 31, Certifications

4. We note that the identification of the certi fying individual at the beginning of the
certification required by Exchange Act Rule  13a-14(a) also includes the title of
the certifying individual. In future filings please do not  include the title
identification of the certifying individual at  the beginning of the certification.
Refer to Item 601 (31) of Regulation S-B.

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a cover letter with your
response that keys your responses to our  comments and provides any requested

Joseph D’Agostino
Milestone Scientific, Inc. May 19, 2008 Page 3  information.  Detailed cover letters greatly facilitate our  review.  Please submit your
cover letter on EDGAR.  Pleas e understand that we may ha ve additional comments after
reviewing your responses to our comments.   We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
‚ the company 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 Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
You may contact Dennis Hult, Staff Accountant, at (202) 551-3618 or myself if
you have questions regarding comments on the financial statements and related matters.
Please contact me at (202) 551-3603 with any other questions.  In this regard, do not
hesitate to contact Angela J. Crane, Accounting Branch Chief, at (202) 551-3554.
          S i n c e r e l y ,             J a y  W e b b             Reviewing Accountant