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SEC Company Response from INTERDENT INC (CIK 0001072765) — Oct 11, 2005

INTERDENT INC (CIK 0001072765)
Date: Oct. 11, 2005 · CIK: 0001072765 · Accession: 0001104659-05-048143

AI Filing Summary & Sentiment

File numbers found in text: 333-124080

Referenced dates: October 7, 2005

Date
Oct. 11, 2005
Author
By
Form
CORRESP
Company
INTERDENT INC (CIK 0001072765)

Letter

Securities and Exchange Commission Division of Corporation Finance 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”) have previously requested, pursuant to an acceleration request letter dated October 7, 2005, 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 “Acceleration Request”).

The Registrants hereby supplement the Acceleration Request by providing the following contact information for notices regarding the Acceleration Request:

Robert Hill

Chief Financial Officer

InterDent Service Corporation

222 N. Sepulveda Blvd., Suite 740

El Segundo, CA 90245

Telephone: (310) 765-2470

Facsimile: (310) 640-9897

Email: HillR@InterDent.com

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 11,
2005

VIA EMAIL 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”) have previously
requested, pursuant to an acceleration request letter dated October 7,
2005, 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 “Acceleration Request”).

 The Registrants hereby supplement the
Acceleration Request by providing the following contact information for notices
regarding the Acceleration Request:

Robert Hill

Chief Financial Officer

InterDent Service Corporation

222 N. Sepulveda Blvd., Suite 740

El Segundo, CA 90245

Telephone:  (310) 765-2470

Facsimile:  (310) 640-9897

Email:  HillR@InterDent.com

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

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