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[CONFIDENTIAL TREATMENT REQUESTED BY Dover Saddlery, Inc.] / [TEXT REDACTED] INDICATES MATERIAL
THAT HAS BEEN OMITTED AND FOR WHICH CONFIDENTIAL TREATMENT HAS BEEN REQUESTED. ALL SUCH OMITTED
MATERIAL HAS BEEN FILED WITH THE SECURITIES AND EXCHANGE COMMISSION PURSUANT TO 17 C.F.R. @200.83

CONFIDENTIAL

FOIA CONFIDENTIAL TREATMENT REQUEST

October 25, 2005

H. Christopher Owings

Assistant Director

Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE — Mail Stop 3561

Washington, D.C. 20549

    Re:

    Dover Saddlery, Inc.

Registration Statement on Form S-1

File No. 333-127888

Dear Mr. Owings:

          On behalf
of our client, Dover Saddlery, Inc., a Delaware corporation (the
“Company” or “Dover Saddlery”), please
find for review by the Securities and Exchange Commission (the “Commission”) four (4) copies of
Amendment No. 2 to the Registration Statement on Form S-1, File No. 333-127888, of the Company (as
amended, the “Registration Statement”), two (2) of which are marked to show changes to the
Registration Statement filed on October 5, 2005. The Registration Statement has been revised to
respond to the comments of the Staff of the Commission (the “Staff”) that were contained in your
letter dated October 21, 2005 (the “Comment Letter”) and to effect such other changes as the
Company deems appropriate.

          Set forth below are the responses of the Company to the comments in the Comment Letter. For
ease of reference, each comment contained in the Comment Letter is printed below in bold and is
followed by the response of the Company. Page numbers refer to page numbers of the Registration
Statement as submitted on the date of this letter.

General

    1.

    We note your response to comment 12 in our letter dated September 23, 2005. The revised
disclosure and Exhibits 10.25 and 10.26 reflect that the redemption agreement was initially
executed on August 25, 2005 — the day before you filed this registration statement — but

    Confidential Treatment Requested By Dover Saddlery, Inc.

    DOVR 001

H. Christopher Owings

October 25, 2005

Page 2

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    closed on September 14, 2005, which is subsequent to the filing
of the registration statement. Please provide us with an analysis of whether the redemption agreement was completed in a
manner consistent with Rule 152 under the Securities Act. In this regard, we note that the
Exhibit 10.26 letter agreement solely amends the closing date of the redemption agreement
to September 14, 2005.

    We note that Exhibit 10.26 only extended the closing date of the above referenced
redemption agreement (the “Redemption Agreement”) from September 15, 2005
to September 16, 2005, which is the date on which the transaction did, in fact, close.
Accordingly, we believe the above references to September 14, 2005 are errors.

    Citizens Ventures, Inc. is a large institutional accredited investor and was the only
entity making an investment decision with respect to the Redemption Agreement included as
Exhibit 10.25 to the Registration Statement. The redemption of shares of capital stock
held by Citizens Ventures, Inc. was related to the Company’s obligation, as provided in
its Amended and Restated Certificate of Incorporation to redeem the shares held by
Citizens Ventures, Inc. on September 10, 2005. As noted by the Staff, the Redemption
Agreement was executed prior to the Company’s first filing of the Registration Statement.
As provided in the Redemption Agreement, the obligation of Citizens Ventures, Inc. to
close the transaction contemplated therein was unconditional and no investment decision
was available to be made by Citizens Ventures, Inc. after the filing of the registration
statement. As noted above, the amendment included as Exhibit 10.26 to the Registration
Statement was not a renegotiation of the terms of the agreement and therefore such
amendment should not constitute a new offering. As a result, under the guidance provided
by the Staff as set forth in the Black Box Incorporated and Squadron, Ellenoff, Pleasant &
Leher no-action letters, with respect to Rule 152 under the Securities Act of 1933, as
amended, we believe the Company completed the transactions contemplated by the Redemption
Agreement in a manner consistent with Rule 152 and is, therefore, protected by the safe
harbor provided thereby.

    2.

    Also, we note in this amendment new disclosure and new exhibits related to an amended and
restated subordination agreement dated September 16, 2005, which again is subsequent to the
filing of the registration statement. In particular, we note that as reflected in Exhibit
10.32, you entered into a warrant purchase agreement to sell common
shares subsequent to the filing of the registration statement.

    Confidential Treatment Requested By Dover Saddlery, Inc.

    DOVR 002

H. Christopher Owings

October 25, 2005

Page 3

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THAT HAS BEEN OMITTED AND FOR WHICH CONFIDENTIAL TREATMENT HAS BEEN REQUESTED. ALL SUCH OMITTED
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    Please provide us with an analysis of whether the
private warrant purchase agreement for common shares should be integrated with your public
offering of common shares.

    Subsequent to the first filing of its Registration Statement, the Company issued to
Patriot Capital Funding, Inc. a promissory note and a warrant to purchase shares of the
Company’s common stock in connection with a loan being made by Patriot Capital Funding,
Inc. to the Company. The purpose of the loan, including the issuance by the Company of
the promissory note and the related warrant to Patriot Capital Funding, Inc., was to provide
the required cash to enable the Company to consummate the transaction with Citizens
Ventures, Inc. as contemplated by Exhibit 10.25. Patriot Capital Funding, Inc. is a large
institutional accredited investor and was the only entity making an investment decision
with respect to the issuance of the promissory note and warrant pursuant to the note and
warrant purchase agreement included as Exhibit 10.32. The sale and issuance of the
promissory note and warrant to Patriot Capital Funding, Inc. would be a valid private
placement if viewed separately. Accordingly, under the guidance provided by the Staff as
set forth in the Black Box Incorporated and Squadron, Ellenoff, Pleasant & Leher no-action
letters, we believe the sale and issuance of the promissory note and warrant pursuant to
the note and warrant purchase agreement should not be integrated with the Company’s public
offering of shares of its common stock.

Summary Historical Financial Information, page 4

    3.

    We note your response to comment 8 in our letter dated September 23, 2005. However, in
footnote (1) on pages 4 and 27, you still disclose that, “we also use EBITDA to determine our
compliance with some of the covenants under our revolving credit facility and subordinated
notes.” Please remove this reference or include a reconciliation of EBITDA to operating cash
flows or whatever directly comparable cash flow measure exists in GAAP.

    In response to the Staff’s comment, the Company has removed the aforementioned references
from the prospectus.

    4.

    We note your response to comment 9 in our letter dated September 23, 2005. Please revise your
disclosures to include disclosure of cash flows from operations, cash flows from investing
activities, and cash flows from financing activities in addition to your presentation of

    Confidential Treatment Requested By Dover Saddlery, Inc.

    DOVR 003

H. Christopher Owings

October 25, 2005

Page 4

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    capital expenditures. Please ensure your presentation is consistent with the Summary of
Historical Financial Information on page 4 and Selected Financial Data on page 26.

    The Company acknowledges the Staff’s comments and has revised the prospectus accordingly.

Critical Accounting Policies, page 39

    5.

    We note your response to comment 15 in our letter dated September 23, 2005. Your discussion
of changes and trends associated with the underlying accounts focuses strictly on reserves
from the balance sheet perspective. Please also disclose changes and trends from the income
statement perspective. For example, your discussion of
merchandise inventories should quantify the amount of expenses that you recorded in each
period for allowances and discuss any trends or significant changes. Your discussion of
revenue recognition should highlight any changes in historical sales return rates or the
lack of any changes.

    The Company acknowledges the Staff’s comments and has revised the prospectus accordingly.

Plan of Distribution, page 76

    6.

    We note your response to comment 18 in our letter dated September 23, 2005. With particular
regard to the supplemental “Open IPO Auction Process Materials” you have provided us, please
tell us to whom and how you will deliver the final piece, which appears to be a targeted
announcement. In addition, to the extent you intend it to comply with Rule 134, please tell us
why it is appropriate to list your 1-800 number and website, and include the bottom
portion‘s suggestion to forward the message to friends and family.

    WR Hambrecht + Co has informed the Company that they have scheduled a conference call for
Tuesday, October 25th with Mark Vilardo of the Office of the Chief Counsel of the
Commission to discuss the supplemental auction materials. All auction process materials
will be in compliance with Rule 134 and the prior guidance of the Staff provided in
connection with the Staff’s review of auction process materials used in prior OpenIPOs.

    Confidential Treatment Requested By Dover Saddlery, Inc.

    DOVR 004

H. Christopher Owings

October 25, 2005

Page 5

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Commissions and Discounts, page 76

    7.

    Please refer to the last sentence of this subsection. Please confirm that the information on
websites maintained by any selected dealer or selling group members is limited to the
electronic prospectus and other information permitted by Rule 134.

    The nature of the process of forming the selling group is such that the final list of
selling group members and the allocation of shares among those members typically is not
made until the day of pricing. Because the underwriters will not know who the members of
the selling group are, and what their plans for posting the prospectus or other offering
information on their website may be, until after the auction is run and shares allocated,
the Company is unable at this time to confirm any selling group member’s plans for posting
the prospectus or any other information on their website. However, W.R. Hambrecht + Co.,
LLC, the lead manager, has advised the Company that in accepting the invitation to join
the selling group, each member of the selling group represents to W.R. Hambrecht + Co.,
LLC as follows:

    “We represent that we will conduct all of our activities with respect to the offering in
compliance with Section 5 of the Securities Act of 1933, as amended.”

The OpenIPO Auction Process, page 76

    8.

    Please revise to disclose that you will deliver to bidders a notice of effectiveness of the
registration statement and of the date that the auction will close. This notice is included in
your supplemental materials, but does not appear to be discussed here in the Plan of
Distribution. Also, please revise the notice and your disclosure to clarify that this notice
is sent when you request effectiveness of the registration statement.

    WR Hambrecht + Co has informed the Company, and the Company respectfully advises the
Staff, that the paragraph on page 77 of the Plan of Distribution under Effectiveness of
the Registration Statement states “After the registration statement relating to this
offering has become effective, potential investors who have submitted bids to the
underwriter or a dealer will be contacted by e-mail, telephone or facsimile. Potential
investors will be advised that the registration has been declared effective and that the
auction may close in as little as one hour following effectiveness.” In

    Confidential Treatment Requested By Dover Saddlery, Inc.

    DOVR 005

H. Christopher Owings

October 25, 2005

Page 6

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    addition, the
third paragraph under Prior to Effectiveness of the Registration Statement states
“Approximately two business days prior to the registration statement being declared
effective, prospective investors will receive, by e-mail, telephone or facsimile, a notice
indicating the proposed effective date.” WR Hambrecht + Co has advised the Company that
neither of these notices are necessarily sent at the same time as the Company requests
effectiveness of the registration statement, therefore the Company has not further revised
this disclosure. The notice of the proposed effective date of the registration statement
will be sent to prospective investors as soon as the Company and the underwriter
determines the date on which they plan to go effective, which may or may not be the
precise time that the Company and the underwriter submit their acceleration request.

    WR Hambrecht + Co has further advised the Company that WR Hambrecht + Co recently
submitted the Plan of Distribution for OpenIPO to the Office of Chief Counsel for the
review and comment of the Office of Chief Counsel, which was conducted by Joe Babits,
Carol McGee and David Lynne of that office. Their review and comment concluded in
approximately May of 2005 and WR Hambrecht + Co has incorporated all of their comments in
the current Plan of Distribution. The purpose of this review was to ensure that OpenIPO
was not viewed unfavorably by prospective issuers because of the possibility that the
Staff’s review of the OpenIPO Plan of Distribution would result in unusual delay
associated with extensive comment and revision of the registration statement disclosure. WR
Hambrecht + Co has further advised the Company that WR Hambrecht + Co has completed 14
initial public offerings via OpenIPO during the past five years, and has had extensive
dialog with the staff regarding OpenIPO, the auction process and the Plan of Distribution
disclosure in connection with each offering. The current disclosure has evolved as a
result of the prior comment and review of examiners in each of the 14 offerings as well as
the recent review of the Office of Chief Counsel and reflects all of their comments. WR
Hambrecht + Co has noted to the Company that the OpenIPO process and disclosure that are
contemplated for the Company’s offering are materially identical to the process and
disclosure that has received the benefi