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Via EDGAR and Email

September 24, 2025

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Nicholas O’Leary

Division of Corporation Finance

Re: Park Dental Partners, Inc.

Registration Statement on Form S-1

Filed September 3, 2025

File No. 333-290001

Dear Mr. O’Leary:

On behalf of our client,
Park Dental Partners, Inc., a Minnesota corporation (the “Registrant”), we are responding to the
comments of the Staff of the Division of Corporate Finance (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) set forth in the letter, dated September 17, 2025, with
respect to the Registrant’s Registration Statement on Form S-1 filed with the Commission on September 3, 2025, File
No. 333-290001 (the “Registration Statement”). For the convenience of the Staff, each of the
Staff’s comments is included in bold and italics and is followed by the corresponding response of the
Registrant. Unless the context indicates otherwise, references in this response letter  (this “Letter”)
to “we,” “us,” and “our” refer to the Registrant.

Concurrent with the
submission of this Letter, the Registrant is filing  Amendment No. 1 to
Registration Statement on Form S-1/A (“Amendment No. 1”). Capitalized terms used but not
otherwise defined in this Letter shall have the meanings assigned to such terms in the Registration Statement.

Registration Statement on Form S-1 Filed
September 3, 2025

Underwriting

Directed Share Program, page 119

 1. We note your disclosure
                                            here and in other parts of the prospectus regarding your directed share program, including
                                            that the relevant shares will be offered to certain individuals, including your directors,
                                            executive officers and employees. Please expand your disclosure to address the process that
                                            prospective participants will follow to participate in the program, the manner in which you
                                            will communicate with prospective participants about the program, when and how you will determine
                                            the allocation for the program, whether such allocation will change depending on the interest
                                            level of potential participants, and any other material features of the program. Please also
                                            clarify the extent to which any of your directors or officers have indicated an interest
                                            in purchasing shares in your offering.

Response:

The Registrant acknowledges the
Staff’s comment and has revised the disclosure in Amendment No. 1, on pages 105 and 120, to provide the noted information.
On September 3, 2025 following the public filing of the registration statement for this offering with the Securities and Exchange Commission,
prospective participants in the Registrant’s directed share program (the “Program”), including, but not
limited to, directors, officers, and other employees of the Registrant (“Participants”), were notified of
the administrative procedures, such as procedures to open an account with the underwriters, to be offered an opportunity to participate in
the Program. An invitation to participate in the Directed Share Program does not guarantee that the participant will receive an allocation of shares.
Accordingly, we cannot provide any assurance that any director, officer, employee, or participant will receive an invitation or an allocation
in the reserved share program.

Under the Program, Participants
will have the option to acquire an aggregate of up to 10% of the total shares offered in the offering at the same price as any other
investor who purchases shares in the Offering. Participants will be able to elect to participate in the Program via completing a
Northland Securities, Inc. (“Northland Securities”) account creation form, signing a certification, and
indicating a preliminary dollar amount they intend to invest in the Program. Northland Securities an underwriter in this offering, will administer the Program. The Registrant currently anticipates that each Participant must invest a minimum of $10,000, and maximum
investments under the Program are expected to be $100,000 for directors and officers of the Registrant and $200,000 for all other Participants.

The Registrant anticipates that
allocation priority will be structured into three tiers: (i) affiliated dentists of the Registrant; (ii) directors, officers, and
other employees of the Registrant; and (iii) all other Participants. Participants in Tier II will only receive an allocation if Tier
I Participants do not purchase their full allocation, and Tier III Participants will only receive an allocation if Participants in
Tier I and Tier II do not purchase their full allocation. At the time of the Offering, Northland Securities will review Participant
interest level and determine final allocations, including pro rata allocation within priority tiers. Certain of our directors and
officers have indicated interest in purchasing shares under the Program, and each director or officer who purchases shares under the
Program, if any, will be subject to the maximum investment limitations and other terms and conditions of the Program that are
generally applicable to all Participants. All shares acquired by existing shareholders, directors, or officers of the Registrant
pursuant to the Program will be subject to a 180-day lockup agreement. As disclosed in the “Principal Shareholder”
section on page 105 of Amendment No. 1, the share information presented in the table of beneficial ownership set forth in that
section does not include any shares purchased under the Program.

Note 1. Nature of Business and Summary of Significant
Accounting Policies, page F-23

 2. In regard to the August 2025
                                            conversion of all previously outstanding Class A-1, Class A-2 and Class A-3
                                            shares to new Common Stock on a 1:1 basis, your disclosures on page F-20 of the Amended
                                            Draft Registration Statement submitted on July 29, 2025 indicate that the different
                                            classes of Class A common stock received different dividends per unrestricted shares.
                                            Please address whether any consideration was given to these differences including whether
                                            preferential rights were given to certain classes and correspondingly your consideration
                                            of the accounting impact of any preferential rights. Please also address what consideration
                                            you gave as to whether the two-class method of EPS should be used prior to the August 2025
                                            conversion. Refer to ASC 260-10-45-59A through 45-70.

Response:

The Registrant acknowledges the
Staff’s comment and confirms that the August 2025 conversion to one designation of common stock obligates the Registrant
to report financial results, including earnings per share (“EPS”), with the one class of equity in
Amendment No. 1. In reaching this conclusion, the Registrant considered guidance within the Division of Corporate Finance’s
Financial Reporting Manual, noting that Section 13500 states, “stock splits also require retrospective presentation.”
Given that the August 2025 change resulted in exchanging one denomination of equity for another, the Registrant concluded that the
conversion was in substance a stock split, and that the guidance applied.

Prior to the conversion, the
Registrant’s articles of incorporation and bylaws did not grant preferential rights to any of the A-1, A-2, or
A-3 shares and only one class of Common Stock existed.

In August 2024 and December 2024,
the Board of Directors of the Registrant declared special dividends to shareholders of all three share denominations (the
 “2024 Dividends”). Prior to the 2024 Dividends, the Registrant distributed profits through incentive
bonuses under its “discretionary shareholder bonus” process, as described on page 21 in  Amendment No. 1. The 2024
Dividends were intended to provide a continuation of the distribution of profits practices that were established prior to the
Registrant’s 2023 re-organization. The dividend rates established for each denomination of shares were determined based on
the projected profit contribution from each denomination of stock aligned with their respective affiliated dental practice. The 2024
Dividends were only distributed to dentists with an ownership interest in the Registrant, and were not distributed to non-equity
owning dentists employed by the Registrant. The intent of the 2024 Dividends was to provide a similar profit distribution to
shareholders consistent with their ownership at the time of the 2023 reorganization.

At the time that the 2024
Dividends were declared, the Registant communicated to its shareholders that the 2024 Dividends were not intended to establish an
ongoing expectation or obligation to continue such distributions. The Registrant notes that no  dividends have been declared in
2025. See the table below for a summary of the 2024 Dividends in comparison to shareholder ownership interests and 2024 profit
contribution percentages. Had the Registrant calculated EPS using the two-class method the adjustment for the numerator for each
denomination of stock is calculated below in the immaterial preferential treatment column.

    Share Denomination
    Unrestricted

 Shares

 Outstanding
    Dividend per

 Share
    Dividend
    Dividend

 Distribution
    Ownership

 percentage at

 time of

 restructuring
    2024 Profit

 Margin

 Contribution %
    Immaterial

 preferential

 treatment

    A-1
    1,089,139
    4.68
    5,097,171
    76 %
    83.3 %
    76 %
    1,030,496

    A-2
    629,573
    2.29
    1,441,722
    21 %
    15.0 %
    23 %
    (909,005 )

    A-3
    77,688
    2.17
    168,583
    3 %
    1.7 %
    1 %
    (121,492 )

    Total
    1,796,400

    6,707,476
    100 %
    100 %
    100 %
    -

Based on these facts and
circumstances and the Registrant’s and its shareholders’ intent, the Registrant concluded that outside of the 2024
Dividends, the Board of Directors of the Registrant did not plan to distribute dividends or earnings on a preferential basis. In
August 2025, the Registrant converted the outstanding denominations of common stock to a single class of common stock, which
resulted in a different EPS calculation and as per the Staff’s guidance quoted above, the Registrant retrospectively restated
its financial statements to reflect the conversion, including within the presentation of EPS.

Note 16. Variable Interest Entities, page F-41

 3. We note your response to
                                            comment 11. Please expand your disclosures to disclose the significant terms and corresponding
                                            effects of the contractual arrangements that resulted in your determination that no amounts
                                            should be allocated to non-controlling interests pursuant to ASC 810-10-45-18 through 45-21.
                                            We note that the Administrative Resources Agreement restricts the dental practice from making
                                            any distributions without Park Dental Partner’s unilateral consent. Please disclose whether
                                            the dental practice has a cumulative right to profits that could be distributed to the noncontrolling
                                            interests in the future upon Park Dental Partner’s consent or upon termination of the Administrative
                                            Resources Agreement.

Response:

The Registrant acknowledges the
Staff’s comment and has revised the disclosure in Amendment No. 1, on page F-41, to provide the significant terms
and corresponding effects of the contractual arrangements that resulted in the Registrant’s determination that no amounts
should be allocated to non-controlling interests.  The Registrant has also revised the disclosure on page F-41 to clarify that
the applicable shareholder agreement appended to each Administrative Resource Agreement between the Registrant and the affiliated
dental practices does not allow for any distributions (whether for liquidation or non-liquidation purposes) without the approval of
the Registrant.

If you have any questions or regarding the filing
or this Letter, please contact me at (612) 604-6729.

Very truly yours,

    WINTHROP & WEINSTINE, P.A.

    /s/ Philip T. Colton

    Philip T. Colton

cc: Peter G. Swenson (via email)

  Vincent M. Pecora, Esq., Winthrop & Weinstine,
P.A.