SEC Company Response from INTERDENT SERVICE CORP (CIK 0001323543) — Jul 11, 2005
INTERDENT SERVICE CORP (CIK 0001323543)
Date: July 11, 2005 · CIK: 0001323543 · Accession: 0001047469-05-019221
AI Filing Summary & Sentiment
File numbers found in text: 333-124080
Referenced dates: June 28, 2005
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 5:00 p.m. Eastern Time on Wednesday, July 13, 2005, or as soon thereafter as is practicable. Please be advised that the Registrants will file Amendment No. 2 to the above referenced Registration Statement in response to comments received from the staff of the Securities Exchange Commission (the "Commission") by letter dated June 28, 2005. The Registrants hope to file Amendment No. 2 on or prior to the requested effective date. The Registrants will withdraw their acceleration request if Amendment No. 2 has not been filed prior to such date.
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 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
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InterDent Service Corporation
InterDent, Inc.
222 N. Sepulveda Boulevard, Suite 740
El Segundo, California 90245
Tel. (310) 765-2400
Fax. (310) 640-9897
July 11,
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 5:00 p.m. Eastern Time on Wednesday, July 13,
2005, or as soon thereafter as is practicable. Please be advised that the Registrants will file Amendment No. 2 to the above referenced Registration Statement in response to comments received
from the staff of the Securities Exchange Commission (the "Commission") by letter dated June 28, 2005. The Registrants hope to file Amendment No. 2 on or
prior to the requested effective date. The Registrants will withdraw their acceleration request if Amendment No. 2 has not been filed prior to such date.
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 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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