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SEC Company Response from Park Dental Partners, (PARK) — Nov 24, 2025

Park Dental Partners, Inc.
Date: Nov. 24, 2025 · CIK: 0002069604 · Accession: 0001104659-25-115347

Offering / Registration Process Regulatory Compliance Business Model Clarity

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File numbers found in text: 333-290001

Date
November 24, 2025
Author
Very
Form
CORRESP
Company
Park Dental Partners, Inc.

Letter

November 24, 2025

VIA EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street N.E.

Washington, DC 20549

Attention: Katherine Bagley; Terence O'Brien; Nicholas O'Leary; Nudrat Salik;

Re: Park Dental Partners, Inc. Registration Statement on Form S-1, as amended (Registration No. 333-290001)

Ladies and Gentlemen:

Pursuant to Rule 461 of the General Rules and Regulations (" Rule 461 ") under the Securities Act of 1933, as amended, Park Dental Partners, Inc. (the " Company ") hereby requests that the Securities and Exchange Commission (the " Commission ") take appropriate action to cause the above-referenced Registration Statement on Form S-1, as amended (the " Registration Statement ") to become effective at 4:00 p.m. Eastern Time, on November 25, 2025, or as soon thereafter as practicable.

If there is any change in the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may be made by an executive officer of the Company or by any attorney from the Company's counsel, Winthrop & Weinstine, P.A.

The Company understands that the representative of the underwriters, on behalf of the prospective underwriters of the offering, has joined in this request in a separate letter filed with the Commission today.

Please contact Mr. Philip T. Colton of Winthrop & Weinstine, P.A. at (612) 604-6729 or via e-mail at pcolton@winthrop.com with any questions you may have concerning this request. In addition, please notify Mr. Colton when this request for acceleration has been granted.

( Signature page follows )

Very
truly yours,
Park Dental Partners, Inc.

Show Raw Text
CORRESP
 1
 filename1.htm

 November 24, 2025

 VIA EDGAR

 Division of Corporation Finance

 Office of Trade & Services

 U.S. Securities and Exchange Commission

 100 F Street N.E.

 Washington, DC 20549

 Attention:          Katherine Bagley; Terence
O'Brien; Nicholas O'Leary; Nudrat Salik;

 Re: Park Dental Partners, Inc. Registration Statement on
Form S-1, as amended (Registration No. 333-290001)

 Ladies and Gentlemen:

 Pursuant to Rule 461
of the General Rules and Regulations (" Rule 461 ") under the Securities Act of 1933, as amended, Park Dental
Partners, Inc. (the " Company ") hereby requests that the Securities and Exchange Commission (the " Commission ")
take appropriate action to cause the above-referenced Registration Statement on Form S-1, as amended (the " Registration
Statement ") to become effective at 4:00 p.m. Eastern Time, on November 25, 2025, or as soon thereafter as practicable.

 If there is any change in
the acceleration request set forth above, the Company will promptly notify you of the change, in which case the Company may be making
an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may
be made by an executive officer of the Company or by any attorney from the Company's counsel, Winthrop & Weinstine, P.A.

 The Company understands that
the representative of the underwriters, on behalf of the prospective underwriters of the offering, has joined in this request in a separate
letter filed with the Commission today.

 Please contact Mr. Philip
T. Colton of Winthrop & Weinstine, P.A. at (612) 604-6729 or via e-mail at pcolton@winthrop.com with any questions you
may have concerning this request. In addition, please notify Mr. Colton when this request for acceleration has been granted.

 ( Signature page follows )

 Very
 truly yours,

 Park Dental Partners, Inc.

 By:
 /s/ Peter Swenson

 Name:
 Peter Swenson

 Title:
 Chief Executive Officer and Director

 ( Signature Page to Issuer Acceleration
Request )