<PAGE>
[LETTERHEAD OF GENTLE DENTAL SERVICE CORPORATION]
May 20, 1998
VIA FACSIMILE
- -------------
Division of Corporate Finance
U.S. Securities and Exchange Commission
450 5th Street, N.W.
Washington, D.C. 20549
Attention: Gary Tomura
Re: Gentle Dental Service Corporation Application for Withdrawal of
Registration Statement, File No. 333-44037 (the "Registration
Statement")
Dear Ladies and Gentlemen:
Gentle Dental Service Corporation, a Washington corporation (the
"Company"), hereby amends its application to withdraw the Registration Statement
in order to exclude from such application Exhibits 10.34-10.41, 10.48 and 10.50
to the Registration Statement which the Company has incorporated by reference in
its Annual Report on Form 10-KSB for the year ended December 31, 1997.
If you have any questions or require further information with regard
hereto, please contact Robert I. Newton of McDermott, Will & Emery at (949)
757-7103.
Very truly yours,
GENTLE DENTAL SERVICE CORPORATION
By /s/ MICHAEL T. FIORE
------------------------------
Michael T. Fiore
Chief Executive Officer