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SEC Company Response from Park Dental Partners, (PARK) — Nov 26, 2025

Park Dental Partners, Inc.
Date: Nov. 26, 2025 · CIK: 0002069604 · Accession: 0001104659-25-116371

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File numbers found in text: 333-290001

Date
November 25, 2025
Author
Jeff Peterson
Form
CORRESP
Company
Park Dental Partners, Inc.

Letter

PARK DENTAL PARTNERS, INC.

2200 County Road C West, Ste. 2210

Roseville, Minnesota

November 26,

VIA EDGAR

United States Securities and Exchange Commission

100 F. Street, NE

Washington, DC

Division of Corporation Finance

Attn: Katherine Bagley

Re: Park Dental Partners, Inc.

Registration Statement on Form S-1, as amended (Withdrawal of Prior Acceleration Request and Renewed Request for Acceleration under Rule 461)

File No. 333-290001

Ladies and gentlemen:

We refer to (i) the registration statement on Form S-1 (File No. 333-290001) (as amended, the "Registration Statement") of Park Dental Partners, Inc. (the "Company") and (ii) our letter to you dated November 25, 2025 (the "Prior Acceleration Request"), in which we joined in the request of the Company to accelerate the effective date of the Registration Statement to 4:00 p.m., Eastern Time, on November 25, 2025, or as soon thereafter as practicable, or at such later time as the Company or its counsel may have requested via telephone call to the staff. We hereby withdraw the Prior Acceleration Request.

Pursuant to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of 1933, as amended, Northland Capital Markets Inc., as Representative of the several Underwriters, hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m., Eastern Time, on December 1, 2025, or as soon thereafter as practicable, or at such later time as the Company or its counsel may request via telephone call to the staff .

Pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the security, as many " E-red " copies of the Preliminary Prospectus as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

The undersigned advises that it has complied and will continue to comply, and that it has been informed by the participating underwriters and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.

Thank you,

NORTHLAND CAPITAL MARKETS, INC.

By: /s/ Jeff Peterson

Name: Jeff Peterson

Title: Head of Investment Banking

Show Raw Text
CORRESP
 1
 filename1.htm

 PARK DENTAL PARTNERS, INC.

 2200 County Road
C West, Ste. 2210

 Roseville, Minnesota
55113

 November 26,
2025

 VIA EDGAR

 United States Securities
and Exchange Commission

 100 F. Street,
NE

 Washington, DC
20549

 Division of Corporation
Finance

 Attn:
 Katherine Bagley

 Re:
 Park Dental
 Partners, Inc.

 Registration Statement on Form S-1, as amended (Withdrawal of
 Prior Acceleration Request and Renewed Request for Acceleration under Rule 461)

 File No. 333-290001

 Ladies and gentlemen:

 We
refer to (i) the registration statement on Form S-1 (File No. 333-290001) (as amended, the "Registration Statement")
of Park Dental Partners, Inc. (the "Company") and (ii) our letter to you dated November 25, 2025 (the "Prior
Acceleration Request"), in which we joined in the request of the Company to accelerate the effective date of the Registration Statement
to 4:00 p.m., Eastern Time, on November 25, 2025, or as soon thereafter as practicable, or at such later time as the Company or
its counsel may have requested via telephone call to the staff. We hereby withdraw the Prior Acceleration Request.

 Pursuant
to Rule 461 of the General Rules and Regulations of the U.S. Securities and Exchange Commission under the Securities Act of
1933, as amended, Northland Capital Markets Inc., as Representative of the several Underwriters, hereby requests acceleration of the
effective date of the above-referenced Registration Statement so that it will become effective at 4:00 p.m., Eastern Time, on December 1,
2025, or as soon thereafter as practicable, or at such later time as the Company or its counsel
may request via telephone call to the staff .

 Pursuant
to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably
anticipated to be invited to participate in the distribution of the security, as many " E-red " copies of the Preliminary
Prospectus as appears to be reasonable to secure adequate distribution of the Preliminary Prospectus.

 The
undersigned advises that it has complied and will continue to comply, and that it has been informed by the participating underwriters
and dealers that they have complied with and will continue to comply, with the requirements of Rule 15c2-8 under the Securities
Exchange Act of 1934, as amended.

 Thank you,

 NORTHLAND CAPITAL MARKETS, INC.

 By:
 /s/ Jeff Peterson

 Name:
 Jeff Peterson

 Title:
 Head of Investment Banking