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Standard Dental Labs Inc.

424 E Central Blvd, St. 308,

Orlando, Florida 32801

August 1, 2024

Attorney Jessica Ansart

Division of Corporation Finance

Securities and Exchange Commission

  Re:
  Standard Dental Labs Inc.

Offering Statement
on Form 1-A

File No. 024-12428

Filed April 25, 2024

Dear Mrs. Ansart:

In response to
your letter dated May 23, 2024, the following information is hereby submitted on behalf of Standard Dental Labs Inc. (the “Company”).
Amendment No. 1 to the Offering Statement on Form 1-A is being filed in conjunction with this correspondence. For your convenience, we
have reproduced the Staff’s comments below in italicized text immediately before our response.

Offering
Statement on Form 1-A

Offering Statement on Form
1-A Filed April 25, 2024

Cover Page

 1. Please revise the total proceeds to company column in your table to ensure the
calculation for the low end of the range in amount of common stock offered by the company is correct. This should align with disclosure
elsewhere in your offering circular, such as in the Use of Proceeds on page 12.

Response: We have updated our Registration Statement
as requested.

 2. Please revise to clarify that this offering will begin within two days of the
date of qualification.

Response: We have updated our
Registration Statement as requested.

 3. Please revise the disclaimers as follows or provide us your analysis regarding
why no revision is necessary:

 • Revise to clarify that no sale may be made if the aggregate purchase price is
more than $75 million.

 • Revise to clarify whether this document is accurate as of the date of qualification
and to what extent you have a legal obligation to revise this document after the date of qualification. Clarify whether you intend to
take legal responsibility for oral statements made by persons at the company after the date of this offering statement, or revise to eliminate
this unclear disclosure.

 • Revise the penultimate paragraph to clarify that you are responsible for all
information in this document.

 • Revise the last paragraph to eliminate the inappropriate disclaimer that “all
such summaries are qualified in their entirety by references to the actual documents.”

Response: We have updated our Registration Statement
as requested.

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Offering Circular Summary

Our Company, page 1

 4. The disclosure in the summary should provide a balanced presentation of your
business, including a brief overview of the key aspects of the offering. Please revise your summary as follows:

 • Please revise to clarify the current business activities of each Standard Dental
Labs Inc. and Prime Dental Lab LLC, and to be consistent throughout the document. For example, if true, clarify whether you subcontract
all of the Standard Dental Labs work to Prime Dental Lab LLC, as you disclosed in previous filings. Here, we note on page 24 that “Standard
Dental Labs produces several kinds of dental prosthetics” and on page 25 that “Prime Dental Lab produces roughly 500 dental
prosthetics each month.” We also note your disclosure on page 28 that Standard Dental Labs is in the business of acquiring privately
owned dental lab operations. Please clarify whether you engage in the same business activities under each tradename.

 • Please revise your discussion of your current business activities to include
a brief description of your current dental lab operations, including the products and services you offer.

 • Please revise the disclosure of your activities searching for lab operations
to acquire to provide additional detail regarding how you identify the regional markets and smaller lab operations you target businesses
and to discuss the current status of your expansion activities.

 • Clarify what role your sole officer and employee has in the search and development
operations as compared to day-to-day supervision of current business operations. Revise the risk factors to address the risks associated
with having one executive officer in multiple roles.

Finally, when revising your summary,
balance the disclosure by including disclosure regarding your limited operating history in your current business segment and your history
of net losses.

Response: We have updated our registration statement
as requested.

Risks Related to Our Company

Acquiring additional dental labs is
a key aspect of our business and growth strategy, page 4

 5. Please revise the subheading of this risk factor to ensure it adequately captures
the risk associated with your acquisition strategy set forth underneath it. Refer to Item 105(a) of Regulation S-K.

Response: We have updated our Registration Statement
as requested.

Risks Related to a Purchase of the
Offered Shares

We may seek additional capital that
may result in stockholder dilution or that may have rights senior to those of our common stock, page 8

 6. We note your disclosure on page 60 that you have entered into a purchase agreement
with World Amber Corp. pursuant to which you have the right to direct World Amber Corp. to purchase up to $2,500,000 shares of your common
stock. Please revise this risk factor to also address the potential dilutionary impact to investors from this equity line with World Amber.
Also revise to highlight this agreement in the Summary and Summary Risk Factors with a cross-reference to more detailed disclosure.

Response:
The Equity Line Agreement with World Amber Corp. was terminated and deemed void ab initio; therefore, we do not believe this
additional language is necessary. We have updated the Registration Statement to consistently reflect the void status of this agreement.

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Use of Proceeds, page 12

 7. In your top table of estimated proceeds, your net proceeds amounts do not appear
to be calculated appropriately. Specifically, the gross proceeds less offering expenses do not appear to equal the net proceeds amounts
disclosed. Please revise as necessary.

Response: We have updated our Registration Statement
as requested.

 8. The second table should show the different purposes for which the net proceeds
from the offering will be used as well as the corresponding amount for each purpose pursuant to Item 504 of Regulation S-K. In this regard,
it is not clear why you are adding the cash value of the amount of principal and interest attributable to the conversion of the Convertible
Notes as it does not appear that the net proceeds from the offering will be used to repay this debt. Please revise your disclosures as
necessary. Please also ensure that the amounts are calculated appropriately. For example, we would expect the 25% column to reflect the
application of total gross proceeds of $2 million less $32,500 of offering expenses, which results in net proceeds of $1,967,500.

Response: We have updated our Registration Statement
as requested.

Plan of Distribution, page 16

 9. We note that you “may issue Offered Shares in this offering for non-cash
consideration, including, without limitation, promissory notes, services and/or other consideration without notice to subscribers in this
offering.” Please revise to disclose the all forms of non-cash consideration you intend to offer and their value. Refer to the Note
to Rule 251(a)(1) of Regulation A. Please also substantially revise your offering document, including the Cover Page, Summary and Use
of Proceeds sections, which all assume the offering will be made for cash only, to discuss the non-cash consideration in more detail and
to address how issuing some or all shares for non-cash consideration would impact your offering. Please also revise your risk factors
to address the potential consequences to the company if a substantial amount of shares is sold for non-cash consideration.

Response: We have updated our Registration Statement
as requested.

Selling Stockholder, page 19

 10. Please revise your disclosure here to indicate the nature of Mr. Kim’s relationship
with the company. Refer to Item 507 of Regulation S-K.

Response: After further consideration, we have decided to remove selling shareholders from this filing. We have updated the Registration
Statement accordingly.

Overview of Business over the Last
Five Years, page 23

 11. We note that you entered into an asset purchase agreement with Prime Dental on
August 15, 2022 pursuant to which you paid $700,000 in cash and stock consideration. We note that a final payment of cash consideration
will be due following the receipt of proceeds from the financing associated with this offering. We also note that the share consideration
is subject to a lock-up agreement pursuant to which 12.5% of the total Consideration Shares will be released each quarter provided certain
minimum quarterly targets are achieved. Please revise to ensure all material terms of the asset purchase agreement, lock- up agreement
and amendments thereto are disclosed, including any termination provisions and the minimum quarterly revenue targets that must be achieved.
Please also file the agreements and any amendments thereto as exhibits to this offering circular. Refer to Item 17.6 of Form 1-A.

Response: We have included the asset purchase agreement as an exhibit. We have reviewed and updated the disclosure to ensure all
material terms are included.

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 12. We note your disclosure that the final payment of $70,000 due to Prime Dental
Lab, LLC “is contingent upon the company being successful in achieving a registered financing such as this application.” Please
clarify whether this exempt offering on Form 1-A pursuant to Regulation A constitutes a “registered financing” such that it
would trigger final payment to Prime Dental Lab, LLC. Please revise your disclosure accordingly.

Response: We have updated our Registration Statement
as required.

Our Current Business, page 25

 13. Please revise this section to describe both your business of discovering and
acquiring dental labs and your operating business, including your agreements with Mr. Kim as a subcontractor, as provided in your previous
filing, or advise why that information is no longer applicable.

Response: While we plan to pursue the acquisition of additional dental labs as part of our growth strategy, acquisitions in and
of themselves are not our business. Rather, our business is that of an operating dental lab. We have updated our Registration Statement
to better reflect these facts. All agreements have been included in the filing as exhibits.

 14. We note your disclosure that you have “more than 50 dental clinics as
clients.” Please discuss what types of commercial arrangements you have in place with these clients and whether your business is
dependent on one or a few of these customers. Refer to Item 601(h)(4)(vi) of Regulation S-K.

Response: As per industry standard, we do not
have any commercial agreements with existing customers or suppliers. We have updated our Registration Statement to so state.

 15. We note your disclosure that “Prime Dental Lab products roughly 500 dental
prosthetics each month.” Please revise in an appropriate place in the business section to address the distribution methods of your
products. Refer to Item 601(h)(4)(ii) of Regulation S-K.

Response: We use standard carriers (UPS, FedEx,
etc.) for delivery of prosthetics. Similarly to our response to Comment 14, we do not have commercial agreements with any of these carriers.
We have updated our Registration Statement to so state.

Products and Services, page 26

 16. We note that your dental labs “supply dentists and dental clinics with
dental prosthetics such as crowns, bridges, and implants.” Please revise your disclosure to address the sources and availability
of raw materials for your products and the names of your principal suppliers. Refer to item 601(h)(4)(v).

Response: Raw materials for our products are
readily available from multiple sources. As such, we source our materials from multiple sources such that we do not consider the Company
as having any principal suppliers. We have updated the Registration Statement to so state.

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 17. We note your disclosure that “3D printing and modelling technology has
become more mainstream” and that “going forward [you] plan to purchase the latest and most advanced equipment available in
the sector.” Please revise your risk factors to address any material risks to your business strategy related to your ability to
successfully purchase and integrate into your operations more advanced equipment and technology such as 3D printing and modelling technology.

Response:
We have updated our Registration Statement as requested.

Employees, page 29

 18. Please revise to clarify if the company contracts with the employees working
in the dental labs, or if they have contracts with another entity controlled by Mr. Kim, or some other facts apply. In addition, please
revise to clarify for what aspects of your business operations you use sub-contractors and consultants, and whether you have contracts
with those individuals.

Response:
We have updated our Registration Statement as requested.

Significant Acquisitions, page 29

 19. We note that as part of your August 2022 acquisition of Prime Dental Labs,
you purchased certain “rights, trademarks, intellectual property and intangible assets of the seller.” Please expand your disclosure
in the Business section to include a discussion of these items acquired as well as any patents, trademarks, licenses, franchises, concessions,
royalty agreements or labor contracts you may have, including duration. Please refer to 101(h)(4)(vii) of Regulation S-K.

Response:
We have updated our Registration Statement as requested.

 20. We note you have entered into a subcontractor agreement with Mr. John Kim on
August 31, 2022, which was amended April 30, 2023, and that your business currently depends on Mr. Kim’s ongoing labor, quality control,
and delivery services and management oversight. Please file this agreement as an exhibit to your offering circular. Refer to Item 17.6
of Form 1-A.

Response:
We have filed the agreement as an exhibit as requested.

Management’s Discussion and Analysis,
page 30

 21. Please revise your discussion of your results of operations to provide a comparative
discussion of material changes between periods and provide the specific reasons and factors contributing to these material changes. Your
discussion of revenues should also include a narrative discussion of the extent to which such changes are attributable to changes in prices
or to changes in the volume or amount of products or services being sold or to the introduction of new products or services. See Item
303 of Regulation S-K.

Response:
We have updated the Registration Statement as requested.

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 22. Please revise this section to disclose your equity line arrangement with World
Amber Corp., including all material terms such as termination provisions and events of default. Please also file the purchase agreement
and related registration rights agreement as exhibits to the offering circular, or, in the alternative, tell us why they are not required
to be filed. Refer to Item 17.6 of Form 1-A.

Response:
The Equity Line Agreement with World Amber Corp. was terminated and deemed void ab initio; therefore, we do not believe the
Equity Line Agreement should be filed as an exhibit.

Directors, Executive Officers, Promoters
and Control Persons, page 36

 23. We note that Ms. Ambrosio has served as a Director since April 20, 2023. Please
expand your disclosure here to briefly discuss the specific experience, qualifications, attributes or skills that led to the conclusion
that the Ms. Ambrosio should serve as a director, in light of the registrant’s business and structure. Refer to Item 401(e)(1) of Regulation
S-K.

Response:
We have updated the registration statement as requested.

Certain Relationships and Related Transactions

James Brooks, Sole Officer and a Director,
Controlling Shareholder, page 41

 24. We note that