Jody M. Walker
Attorney At Law
7841 South Garfield Way
Centennial, CO 80122
303-850-7637 telephone jmwalker85@earthlink.net 303-482-2731 facsimile
August 31, 2011
Division of Corporation Finance
Securities and Exchange Commission
100 F. Street N.E.
Washington, D.C. 20549
Re: Strategic Dental Management Corp.
Amendment 4 to Registration Statement on Form S-1
Filed August 24, 2011
File No. 333-172110
Gentlemen:
We have reviewed the Securities and Exchange Commission's recent verbal
comments and have provided the following response.
1. A risk factor has been added as follows to discuss the
potential conflict of interest relating to SofTouch Dental LLC.
12. Our officers currently own and operate SofTouch Dental
LLC, a privately held dental practice. Our officers could have a
conflict of interest relating to business activities and decisions
for SofTouch and the registrant.
SofTouch Dental LLC is in the same line of business as the
proposed activities of the registrant. In addition to a conflict
of interest in the amount of time spent on the two operations as
discussed above, there may be a conflict of interest for our
officers in patient development, staff recruitment and other
related business decisions for SofTouch and the registrant.
2. Exhibit 5, attorney's opinion has been revised to include the
common shares being sold by the selling shareholders.
3. The registrant has researched potential licensing issues in
the state of Arizona relating to the acquiring and opening of dental
practices in Arizona. Based on that in-house research, the registrant
is of the opinion that there are no material risks that would require
additional disclosure in the registration statement.
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
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Jody M. Walker
Attorney At Law