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LETTER TO THE S.E.C.

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Milestone Scientific, Inc.

220 South Orange Avenue

Livingston, NJ 07039

(973) 535-2717

November 15, 2007

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington, D.C. 20549

    Attention:

    Mr. Dennis C. Hult

    Staff Accountant

Milestone Scientific, Inc.

File No. 001-14053

Dear Sirs:

This letter is in response to the Staff’s comment letter dated October 12, 2007 regarding the Form
10-KSB for the year ended December 31, 2006 (the “10-K”) and the Form 10-QSB for the three months
ended June 30, 2007 (the “June 10-Q”) as filed by Milestone Scientific, Inc. As requested in the
letter our responses are keyed to the number of each comment in your letter. For your convenience
we have attached a copy of our form 10-QSB for the quarter ended September 30, 2007, which was
filed on November 13, 2007. If you have any questions regarding the responses to your comments
please feel free to contact me at 973-535-2717 or Stephen Zelnick of Morse, Zelnick, Rose and
Lander at 212-838-8040.

Despite the fact that seven of the nine comments were directed to our 10-K we felt it proper to
address them in the 10-Q for the three months ended September 30, 2007 (the “September 10-Q”). We
will, of course, continue presenting the expanded commentary in our 10-K for 2007 and thereafter as
appropriate.

Your comment:

FORM 10-KSB for the Fiscal Year Ended December 31, 2006 Management’s Discussion and Analysis,
page 15

Summary of Significant Accounting Policies and Significant Judgments and Estimates, page 21

    1.

    We note your discussion of critical accounting policies, but
the disclosures either do not disclose why they are considered
critical accounting policies or they merely
repeat the policies from your significant accounting policies footnote without elaboration.

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    Accordingly, your disclosure does not conform to our expectations for the critical
accounting policies disclosure. For each identified critical accounting policy, please
expand to describe the specific factors that in your view makes each critical. Discuss the
nature of estimates and uncertainties about those estimates inherent to each individual
policy, including how you make those estimates. Discuss how different assumptions, methods
or conditions might effect your financial statements. Revise future filings to comply.

Our response:

1 — We have expanded our discussion in notes 2 and 3 as well as in the “Summary of Significant
Accounting Policies” section in the September 10-Q so as to more clearly state why each applicable
policy is critical and how we make the estimates required to implement the policy. We will do the
same in future filings including our next form 10-KSB.

Your comment:

Liquidity and Capital Resources, page 23

2. 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 that accounts payable
increased $688 thousand over the past year while inventories show a decline. Please address the
impact on your working capital. When you cite changes in components of working capital, explain the
reasons for the changes

Our response:

2 — Under the caption “Liquidity and Capital Resources” in the September 10-Q we have pointed out
the changes in the major components of working capital and explained the reasons for the change.
We will do the same in future filings including in our next form 10-KSB.

Your comment:

    3.

    In your liquidity discussion you note the Company experienced in 2006 negative cash flows of
$l.6 million from operating activities. You conclude by indicating management believes the
Company has sufficient resources to meet its obligations over the next twelve months. This
statement is too general and needs to be more specific. Tell us and in future filings provide
details of expected liquidity needs over the next year. For example, future filings should
disclose

    •

    the expected additional costs to obtain a CE mark and U.S. patent protection,
which you deem necessary to re-introduce your teeth whitening products;

    •

    the planned reductions in operations expenses and/or the impact technology
rights will have on liquidity and

    •

    the existing internal and external capital sources and the circumstances that
are reasonably likely to affect those sources of liquidity.

    Also, consider discussing other sources that the Company is pursuing.

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Our response:

3 — As you can see both under “Summary of Accounting Policies” in Note 1 and in the paragraph
under “Liquidity and Capital Resources” in our September 10-Q we stated that “the Company does not
now have sufficient cash reserves to meet all of its anticipated obligations for the next twelve
months.” We go on to say that we will attempt to improve the Company’s cash flow from operations
but if the Company is unable to generate sufficient cash it will have to seek outside capital which
may, or may not, be available to it on satisfactory terms or at all. An effort is underway to
raise additional debt or equity capital and while we expect that the effort will be successful no
commitments have been obtained to date.

     Since your letter raises the point of additional costs to obtain a CE mark and patent
protection for our teeth whitening product you should be aware that (a) we have received the CE
mark and (b) we have decided to no longer sell our current teeth whitening products and have
written off all associated assets in the third quarter of 2007.

     At the time of the filing of the form 10-KSB for the year ended December 31, 2006 Milestone
was confident that it had sufficient resources and that additional financing could be obtained. In
fact a new $1 million line of credit was entered into on June 28, 2007.

Your comment:

Notes to Financial Statements, page F-7

Note B — Summary of Significant Accounting Policies, page F-7

    4.

    In future filings please consider the need to include in your Summary of Significant
Accounting Policies your accounting policy for allowances for doubtful accounts receivable.

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Our response:

4 — We have explained more clearly our policy for allowances for doubtful accounts in notes 2 and
3, and in the “Summary of Significant Accounting Policies” in our September 10-Q. We will do the
same in future filings including in our next form 10-KSB. Please note, however, that as stated in
Note 7 of the September 10-Q virtually all of our sales are to Henry Schein, Inc., a very large
distributor of dental and medical products, and to a foreign distributor with whom we have been
doing business for some years without any failure on the part of that distributor to make payments
to us when due. Our terms of sale to Henry Schein, Inc. are net 30 days and net 90 days to our
foreign distributor.

Your comment :

Note B8 — Revenue Recognition, page F-8

    5.

    We note your revenue recognition policy disclosure is very generic. Refer to your response
letter dated May 11, 2005, specifically your responses to comments 1, 2 and 3. In future
filings, please revise your revenue recognition policy disclosure to include the more salient
points addressed in your prior responses to us.

Our response:

5 — We have expanded the explanation of our revenue recognition policy in the September 10-Q under
the caption “Summary of Significant Accounting Policies” and will do the same in future filings
including in our next form 10-KSB.

Your comment:

Note H — Stockholders’ Equity, page F-l2

Other Issuances of Common Stock, page F-l3

    6.

    Please provide us with a schedule reconciling the fiscal 2006 common stock issuances as
disclosed in the footnote to the amounts presented in the Statement of Changes in
Stockholders’ Equity and the Statement of Cash Flows.

    7.

    To this regard, tell us and in future flings please explain how each issuance of equity
instruments was valued.

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Our response:

6 — The total value of common stock and options issued for compensation, consulting and vendor
services shown on both the Statement of Cash Flows and on the Statement of Changes in Stockholders’
Equity for the year ended December 31, 2006 is $547,487.

Note H to the financial statements details the following:

Other issuances of Common Stock;

    February

    $
    46,000

    August

    51,250

    September

    20,250

    December

    34,333

    2005 stock issuance to seven consultants with
compensation recognized in 2006 of

    100,501

    2005 stock issued for employee bonuses and
compensation with recognition in 2006 of

    8,333

    Note I states that:

    compensation expense related to
employees recognized in 2006 was

    41,489

    and related to non-employees was

    95,328

    Also, common stock to be issued in settlement
of deferred compensation in 2006 was

    150,000

    Total

    $
    547,484

7 — Any options or warrants that contain the requirement for the recipient to render services in
the future are valued based on the market value on date of issuance and are then revalued quarterly
using the Black-Scholes model. Otherwise, each issuance of equity instruments is valued based on
the market value at time of issuance if issued in connection with stock based compensation or for
services provided by a non-employee. If the instrument is issued in connection with debt it is
valued using the Black-Scholes model and the debt and equity instrument are recorded at relative
fair values. The variables used in the Black-Scholes calculation are disclosed in the last
paragraph of Note I in our form 10-KSB for the year ended December 31, 2006.

Your comment:

Form 10-QSB for the quarterly period ended June 30, 2007

Item 3 Controls and Procedures, page 18

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    8.

    Please expand the first paragraph of the disclosure to incorporate language encompassing the
entire two-sentence definition of disclosure controls and procedures as set forth in Exchange
Act Rule 13a-l5(e). That is, you should also clarify, if true, that your disclosure controls
and procedures are designed to ensure that information required to be disclosed in reports
filed or submitted under the Exchange Act is accumulated and communicated to management to
allow timely decisions regarding required disclosure. Apply in future filings.

    9.

    In future filing, please revise the first paragraph to state whether the disclosure controls
and procedures were effective, as of the end of the fiscal quarter. It is not sufficient to
say “as of the date of their evaluation”. Refer to Item 307 of Regulation S-B.

Our response:

8 and 9 — This has been done under item 3 of the September 10-Q and will be included in future
filings as appropriate.

*     *     *     *     *

As requested, the Company is pleased to confirm that:

it is responsible for the adequacy and accuracy of the disclosures 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 comments as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

If you require any further information please do not hesitate to contact me or Mr. Zelnick, as
noted above.

    Respectfully,

    /s/ Arthur L. Goldberg

    Arthur L. Goldberg

    Acting Chief Financial Officer

xc: Stephen Zelnick, Esq.

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SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-QSB

Mark One

    þ

    QUARTERLY REPORT UNDER SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the Quarterly Period Ended September 30, 2007

OR

    o

    TRANSITION REPORT UNDER SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _________ to _________

Commission File Number 001-14053

MILESTONE SCIENTIFIC INC.

(Exact name of Registrant as specified in its charter)

    Delaware

State or other jurisdiction

or organization)

    13-3545623

(I.R.S. Employer

Identification No.)

220 South Orange Avenue, Livingston, New Jersey 07039

(Address of principal executive office)

(973) 535-2717

(Registrant’s telephone number, including area code)

     Check whether the Issuer (1) has filed all reports required to be filed by Section 13 or 15(d)
of the Exchange Act during the past 12 months (or for such shorter period that the registrant was
required to file such reports), and (2) has been subject to such filing requirements for the past
90 days.      Yes þ     No o

     Indicate by check mark whether the Registrant is a shell company (as defined in Rule 12b-2 of
the Exchange Act).      Yes o     No þ

As of November 6, 2007, the Issuer had a total of 11,787,602 shares of Common Stock, $.001 par
value, outstanding.

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FORWARD LOOKING STATEMENTS

When used in this Quarterly Report on Form 10-QSB, the words “may”, “will”, “should”, “expect”,
“believe”, “anticipate”, “continue”, “estimate”, “project”, “intend” and similar expressions are
intended to identify forward-looking statements within the meaning of Section 27A of the Securities
Act and Section 21E of the Exchange Act regarding events, conditions and financial trends that may
affect Milestone Scientific Inc.’s (“Milestone”)’s future plans of operations, business strategy,
results of operations and financial condition. Milestone wishes to ensure that such statements are
accompanied by meaningful cautionary statements pursuant to the safe harbor established in the
Private Securities Litigation Reform Act of 1995. Prospective investors are cautioned that any
forward-looking statements are not guarantees of future performance and are subject to risks and
uncertainties and that actual results may differ materially from those included within the
forward-looking statements as a result of various factors. Such forward-looking statements should,
therefore, be considered in light of various important factors, including those set forth herein
and others set forth from time to time in Milestone’s reports and registration statements filed
with the Securities and Exchange Commission (the “Commission”). Milestone disclaims any intent or
obligation to update such forward-looking statements.

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MILESTONE SCIENTIFIC INC.

INDEX

    PAGE

    PART I. FINANCIAL INFORMATION

    ITEM 1.

    Financial Statements

    Condensed Balance Sheets September 30, 2007 (Unaudited) and December 31, 2006

    4

    Condensed Statements of Operations Three and Nine Months Ended September 30, 2007 and 2006 (Unaudited)

    5

    Condensed Statements of Changes in Stockholders’ Equity Nine Months Ended September 30, 2007 (Unaudited)

    6

    Condensed Statements of Cash Flows Nine Months Ended September 30, 2007 and 2006 (Unaudited)

    7

    Notes to Condensed Financial Statements (Unaudited)

    8

    ITEM 2.

    Management’s Discussion and Analysis or Plan of Operation

    13

    ITEM 3

    Controls and Procedures

    19

    PART II. OTHER INFORMATION

    ITEM 6.

    Exhibits

    20

    SIGNATURES

    21

    CERTIFICATIONS

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MILESTONE SCIENTIFIC INC.

CONDENSED BALANCE SHEETS

    September 30, 2007

    (Unaudited)

    December 31, 2006

    ASSETS

    Current Assets:

    Cash and cash equivalents

    $
    44,783

    $
    1,160,116

    Accounts receivable, net of allowance for doubtful accounts of $5,000
in 2007 and $16,519 in 2006

    594,779

    346,619

    Royalty receivable

    28,976

    60,107

    Inventories

    1,657,256

    1,323,338

    Advances to contract manufacturer

    1,020,480

    1,077,871

    Prepaid expenses

    72,278

    97,073

    Total current assets

    3,418,552