SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

July 6, 2005

Mr. Breht T. Feigh
Executive Vice President,
Chief Financial Officer and Treasurer
American Dental Partners, Inc.
201 Edgewater drive, Suite 285
Wakefield, MA  01880

Re:	American Dental Partners, Inc.
	Form 10-K for the Fiscal Year Ended December 31, 2004
	Filed March 14, 2005
      Form 10-K/A for the Fiscal Year Ended December 31, 2004
	Filed March 16, 2005
      Form 10-Q for the Period Ended March 31, 2005
	Filed May 9, 2005
	File No. 000-23363

Dear Mr. Feigh:

	We have limited our review to only your financial statements
and
related disclosures and do not intend to expand our review to
other
portions of your documents.  In our comments, we ask you to
provide
us with supplemental information so we may better understand your
disclosures.  Please be as detailed as necessary in your
explanations.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
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.

Form 10-K for the Fiscal Year Ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and results of Operations, page 19

Results of Operations, page 21

Net Revenue, page 21

1. Please explain to us more fully why it is appropriate for you
to
discuss the revenues of the dental practices that you do not
consolidate as if they were your revenues.  Reference the
accounting
literature related to non-GAAP measures in determining the
appropriateness of this usage.

Contractual Obligations, page 27

2. Please explain to us why you feel that the presentation of the
contractual obligations net of reimbursement obligations is
appropriate.  Also explain why it appears that you did not include
interest obligations related to the debt issuances.  Include
specific
references to the applicable guidance within the rules that you
feel
supports this presentation.

Form 10-K/A for the Fiscal Year Ended December 31, 2004

 (2)  Summary of Significant Accounting Policies, page 42

Goodwill and Intangible Assets, page 43

3. Please explain to us the appropriateness of recording the
"estimated fair value of the service agreements [as] the excess of
the purchase price over the estimated fair value of the tangible
assets acquired and liabilities assumed" related to the new
affiliations.  Refer to paragraph 43 of SFAS 141.  Also
demonstrate
to us where you complied with all of the disclosure required by
paragraph 44(a)(3) of SFAS 142.

Insurance, page 44

4. Please tell us the amount of these reserves related to these
insurance exposures.

Form 10-Q for the Period Ended March 31, 2005

Consolidated Statements of Cash Flows, page 5

5. We note that you include a significant expenditure in the
current
period related to "Acquisitions and affiliations, net of cash
acquired."  We note that you also reference a "platform"
affiliation
that occurred in February of 2005 multiple times as a reason that
affected your operations throughout management`s discussion and
analysis.  Please tell us why you felt it appropriate to omit any
significant disclosure related to this apparently significant new
affiliation in your document.

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provide the
requested information.  Detailed letters greatly facilitate our
review.  Please file your letter on EDGAR under the form type
label
CORRESP.  Please understand that we may have 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
filings include all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
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 your letter, 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 comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

You may contact Keira Ino, Staff Accountant, at (202) 551-3659 or
Jim
Atkinson, Accounting Branch Chief, at (202) 551-3674 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3679 with any other
questions.

Sincerely,

Jim B. Rosenberg
Senior Assistant Chief
Accountant
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Breht T. Feigh
American Dental Partners, Inc.
July 6, 2005
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