SecProbe.io

CORRESP
 1
 filename1.htm

 November 26, 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

 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) (Registration 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.
("we," or the "Company") and (ii) our letter to you dated November 25, 2025 (the "Prior Acceleration
Request"), in which we requested 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 our 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 (" Rule 461 ") under the Securities Act of 1933, as amended, 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 December 1, 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 )