Jody M. Walker
                             Attorney At Law
                         7841 South Garfield Way
                          Centennial, CO 80122
303-850-7637 telephone  jmwalker85@earthlink.net 303-482-2731 facsimile

May 13, 2011

Division of Corporation Finance
Securities and Exchange Commission
100 F. Street N.E.
Washington, D.C. 20549

Re:  Strategic Dental Management Corp.
     Registration Statement on Form S-1
     Filed February 8, 2011
     File No. 333-172110

Gentlemen:

We have reviewed the Securities and Exchange Commission's recent
comment letter and have provided the following responses.

Risk Factors
"Our officers have no experience in running multiple dental offices..."
1.   We note your response to our prior comment 10.  Please delete the
first sentence of this risk factor and also remove the disclosure
concerning the increase in production at SofTouch Dental in the send
sentence.  It is not appropriate for a risk fact disclosure to include
statements that serve to mitigate the risk described.

The risk factor has been revised as follows to remove the
mitigating language.

Although our officers have successfully run a single dental
practice, they are not experienced in running several practices
simultaneously.  Our current officers have effective control over
all decisions regarding both policy and operations of our
operations with no oversight from other management. Our success is
contingent upon the ability of these individuals to make
appropriate business decisions in these areas.  However, our
officers have no experience in operating multiple dental
practices. It is possible that this lack of relevant operational
experience could prevent us from becoming a profitable business.

"Our officers have other business activities...
2.  Please revise the heading of this risk factor to make clear, if
true, that your officers may compete directly with the activities of
the registrant.

Business Strategy
3.  We note your response to our prior comment 24.  Please clarify
whether you are referring to SofTouch Dental LLC when you cite to the
"officers" dental practice growth results," clarify what you are
referring to specifically by the "results achieved while consulting,"
and explain the methodology you used to derive the registrant's monthly
and annual projections from these results.


      The disclosure has been clarified as follows

The projections above are based upon SofTouch Dental's practice
growth results and results achieved while consulting for other
dental practices with the last 2 years.  Results were extrapolated
from the actual growth achieved by SofTouch Dental within the
first 2 years the officers purchased and started running the
company.  In addition, results include the revenue generated by
companies that the officer's consulted with and the growth seen by
those companies over a 2 year period.

Thank you for your time and consideration in this matter.  Please do
not hesitate to contact me if you have any questions regarding the
above.

Very truly yours,

/s/Jody M. Walker
------------------------
Jody M. Walker
Attorney At Law