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 June 10, 2025

James Brooks
Chief Executive Officer
Standard Dental Labs Inc.
424 E Central Blvd
Suite 308
Orlando, Florida 32801

 Re: Standard Dental Labs Inc.
 Amendment No. 2 to Offering Statement on Form 1-A
 Filed May 15, 2025
 File No. 024-12428
Dear James Brooks:

 We have reviewed your amended offering statement and have the following
comments.

 Please respond to this letter by amending your offering statement and
providing the
requested information. If you do not believe a comment applies to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your offering statement and the
information you
provide in response to this letter, we may have additional comments. Unless we
note
otherwise, any references to prior comments are to comments in our August 23,
2024, letter.

Amendment No. 2 to Offering Statement on Form 1-A filed May 15, 2025
Report of Independent Registered Public Accounting Firm, page 44

1. Please revise your Form 1-A to provide disclosures regarding your change
in
 accountants similar to those referenced in Item 4 of the Form 1-U. Also,
please
 provide a letter regarding the change in certifying accountant as an
exhibit to the Form
 1-A. Refer to Item 17(9) of Part III of the Form 1-A.
Balance Sheets, page 46

2. In regard to the negative advance payable related party of $7,691,
which your
 disclosures on page 41 indicate are with respect to an excess of
expenses paid by you
 that were incurred by Mr. Brooks, please address the following:
 June 10, 2025
Page 2

 Please further expand your disclosures to address why your
President would have
 been reimbursed amounts in excess of expenses incurred on behalf of
the
 company as well as the terms associated with the repayment.
 Please address what consideration was given to reflecting this as
a receivable
 from a related party instead of as a liability.
 Please confirm that all expenses incurred by your President on the
company's
 behalf have been reflected in your financial statements. Refer to
SAB Topic
 1:B.1.
Statements of Operations, page 47

3. There appears to be a calculation error in your determination of net
loss per common
 share for 2022. Specifically, the net loss per common share does not
appear to equal
 the net loss divided by the weighted average common shares outstanding.
Please
 advise or revise as necessary.
4. If you continue to include statements of operations and stockholders
equity for 2022,
 please tell us how you considered the recapitalization in calculating
the weighted
 average common shares outstanding for 2022. Specifically, it appears the
periods
 prior to the reverse recapitalization should reflect Prime Dental only
and the shares
 issued under the acquisition agreement line item on the statement of
stockholders
 equity should reflect the number of shares retained by Standard Dental,
with amounts
 adjusted for the subsequent stock split. For purposes of computing EPS,
the number of
 shares outstanding for the period from the beginning of the fiscal year
to the date of
 the acquisition should be the number of shares issued by Standard Dental
to Prime
 Dental. For the period from the date of the acquisition to the end of
the fiscal year, the
 number of shares to be used in the calculation of EPS should be the
actual number of
 shares of the combined entity outstanding in that period. The weighted
average
 number of shares to be used in computing EPS would be calculated on the
basis of the
 numbers determined for the two periods as described.
Note 8. Services Agreement with Contracted Operator, page 58

5. We note your response to comment 15. Please address the following:
 We note that the contracted operator is responsible for furnishing
labor, materials,
 supplies, labor and/or goods required to manufacture dental
prosthetics and
 orthodontics. Based on the description of the services provided in
your disclosures
 on page 58 as well as the subcontract agreements filed as exhibits, it
appears that
 all amounts paid under the subcontract agreement are costs incurred
directly
 related to the manufacturing of dental prosthetics. In this regard, it
is not clear
 how you determined that a portion of the amounts paid should be
excluded from
 cost of sales as well as how you came up with the amount to exclude.
Please
 advise.
 Please tell us the specific amounts reflected in general and
administrative
 expenses for each period presented.
 As previously requested, please expand your disclosures in MD&A
related to the
 contracted operator agreement to discuss whether this agreement has
been
 June 10, 2025
Page 3

 renewed and the impact of not being able to do so if it has not been
renewed.
 Specifically we note that the agreement was entered into on August
31, 2022 and
 has an initial term of up to two years. This would indicate that the
agreement may
 terminate on August 31, 2024. We remind you that Instruction 1 to
Item 9A of the
 Form 1-A states that your discussion and analysis shall focus
specifically on
 material events and uncertainties known to management that would
cause
 reported financial information not to be necessarily indicative of
future operating
 results or of future financial condition. This would include
descriptions and
 amounts of matters that have had an impact on reported operations
that are not
 expected to have an impact upon future operations.

 Please contact Nudrat Salik at 202-551-3692 or Terence O'Brien at
202-551-3355 if
you have questions regarding comments on the financial statements and related
matters. Please contact Nicholas O'Leary at 202-551-4451 or Katherine Bagley at
202-551-
2545 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Industrial
Applications and
 Services
cc: Jason Brenkert, Esq.
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