Union Dental Holdings, Inc.
1700 University Drive, Suite 200
Coral Springs, FL 33071
Tel: (954) 575-2252 Toll Free: 1-800-982-2605 Fax: (954) 344-8479
E-Mail: info@uniondentalcorp.com www.uniondental.com
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Union Dental Holdings, Inc. is a publicly traded company on the Over-the-Counter
Stock Exchange and traded under the ticker symbol UDHI. Union Dental Corp. and
Direct Dental Services, Inc., are wholly owned subsidiaries.
September 18, 2008
Securities and Exchange Commission
Washington, D.C. 20549
RE: Union Dental Holdings Inc.
Form 10-KSB for the Fiscal Year Ended
December 31, 2007
Filed March 31, 2008
File No. 000-32563
Dear Sir/Madam:
The following responses are filed in connection with the Commission's
comment letter dated August 21, 2008.
1. With respect to comment no. 1 regarding the filing of a Form S-8 during
the fiscal year ended December 31, 2008:
Please be advised that we have amended the annual report to include a
current consent.
2. With respect to comment no. 2 with reference to Item 8(a) Controls and
Procedures and Management's Report on Internal Controls over Financial
Reporting:
Please be advised that we have amended the annual report to provide a
statement to comply with Item 308(T)(a)(4).
3. With respect to comment no. 3, regarding the certifications:
Please be advised that we have amended the annual report to provide for the
certification as required by Item 601(b)(31) of Regulation S-B.
Union Dental Holdings, Inc. hereby acknowledges that (i) it is responsible
for the adequacy and accuracy of the disclosure in the filings referenced above,
(ii) staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to the filings;
and (iii) the Company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
Should you have further questions, please do not hesitate to contact the
undersigned.
Sincerely,
/s/George Green
George Green, CEO