[Strategic Dental Management Corp. Letterhead]


September 2, 2011

Division of Corporation Finance
United States Securities and Exchange Commission
100 F. Street N.E.
Washington, D.C. 20549
Telephone: (202)551-3121

Re:   Acceleration of Effective Date
      Strategic Dental Management Corp.
      Registration on Form S-1
      File No. 333-172110

Dear Sir or Madam:

Pursuant Rule 461 of the Securities Act of 1933, we hereby request an
acceleration of the effective date of our registration statement on
Form S-1.   We request an effective date of Tuesday, September 6, 2011
at 3:00 p.m. eastern time or as soon thereafter as possible.

We confirm that we are aware of our obligations under the Act.   We
hereby acknowledge that:
  -  should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
  -  the action of the Commission or the staff, acting pursuant to
delegated authority, in delegated authority, in declaring the filing
effective, does not relieve the company from its full responsibility
for the adequacy and accuracy of the disclosure in the filing; and
  -  the company may not assert the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

Thank you for you time and consideration in this matter.   Please do
not hesitate to contact me if you require further information or
documentation regarding this matter.

Very truly yours,

Strategic Dental Management Corp.


By: /s/Brian E. Ray
    -----------------------
    Brian E. Ray
    Chief Executive Officer