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SEC Company Response from INTERDENT INC (CIK 0001072765) — Oct 7, 2005

INTERDENT INC (CIK 0001072765)
Date: Oct. 7, 2005 · CIK: 0001072765 · Accession: 0001047469-05-024120

AI Filing Summary & Sentiment

File numbers found in text: 333-124080

Date
October 13, 2005
Author
By
Form
CORRESP
Company
INTERDENT INC (CIK 0001072765)

Letter

VIA EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Mail Stop 6010 Washington, D.C. 20549 Re:InterDent Service Corporation Registration Statement on Form S-4 (File No. 333-124080)

Dear Ms. Fraser:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, InterDent Service Corporation and InterDent, Inc. (collectively, the "Registrants") hereby request that the effectiveness of the Registration Statement referenced above be accelerated so that such Registration Statement will become effective at 9:00 a.m. Eastern Time on Thursday, October 13, 2005, or as soon thereafter as is practicable.

The undersigned hereby confirms that the Registrants are aware of their responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as amended, as they relate to the proposed exchange offer by InterDent Service Corporation specified in the above captioned Registration Statement. The undersigned acknowledges that:

•should the Securities and Exchange Commission (the "Commission") or its staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•the Registrants may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate your assistance and cooperation in this matter.

Sincerely,
INTERDENT SERVICE CORPORATION

Show Raw Text
CORRESP
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filename1.htm

InterDent Service Corporation

InterDent, Inc.

222 N. Sepulveda Boulevard, Suite 740

El Segundo, California 90245

Tel. (310) 765-2400

Fax. (310) 640-9897

October 7,
2005

VIA EDGAR AND FACSIMILE

Mary
K. Fraser, Esq.

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Mail Stop 6010

Washington, D.C. 20549

Re:InterDent Service Corporation
  Registration Statement on Form S-4 (File No. 333-124080)

Dear Ms. Fraser:

        Pursuant
to Rule 461 under the Securities Act of 1933, as amended, InterDent Service Corporation and InterDent, Inc. (collectively, the "Registrants") hereby request that
the effectiveness of the Registration
Statement referenced above be accelerated so that such Registration Statement will become effective at 9:00 a.m. Eastern Time on Thursday, October 13, 2005, or as soon thereafter as is
practicable.

        The
undersigned hereby confirms that the Registrants are aware of their responsibilities under the Securities Act of 1933, as amended, and the Securities Exchange Act of 1934, as
amended, as they relate to the proposed exchange offer by InterDent Service Corporation specified in the above captioned Registration Statement. The undersigned acknowledges that:

•should
the Securities and Exchange Commission (the "Commission") or its staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose
the Commission from taking any action with respect to the filing;

•the
action of the Commission or its staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from their full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

•the
Registrants may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

        We
appreciate your assistance and cooperation in this matter.

Sincerely,

INTERDENT SERVICE CORPORATION

By:

/s/  ROBERT W. HILL       Robert W. Hill

Chief Financial Officer

INTERDENT, INC.

By:

/s/  ROBERT W. HILL       Robert W. Hill

Chief Financial Officer

2