Mail Stop 6010
April 25, 2006

Via U.S. Mail and Facsimile (717)849-4756

William Jellison
Senior Vice President and Chief Financial Officer
Dentsply International Inc.
221 West Philadelphia Street
York, Pennsylvania 17405

	Re:	Dentsply International Inc.
		Form 10-K for the fiscal year ended December 31, 2005
		Filed March 14, 2006
		File No. 000-16211

Dear Mr. Jellison:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings to those issues we have
addressed in our comments. Where indicated, we think you should
revise your future filings in response to these comments.  If you
disagree, we will consider your explanation as to why our comment
is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspects
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2005

Item 8. Financial Statements and Supplementary Data

Consolidated Statements of Cash Flows, page 51

1. As set forth in paragraph 28 to SFAS 95, the operating
activities
section of an indirect method presentation of cash flows should
begin
with net income or loss.  Your statement does not appear
consistent
with that guidance because your presentation begins with net
income
from continuing operations.  To better conform to SFAS 95, please
appropriately modify your presentation in future filings.

Note 4.  Segment and Geographic Information, page 61

2. We see that you presented five segments in 2004, four segments
in
2005 and plan to report three segments in 2006.  Please tell us
how
you re-organized your operating group structure in 2005 and in
2006.
Explain why these re-organizations resulted in the reductions in
the
numbers of segments reported under SFAS 131.  Please be detailed
and
specific.

3. We see that for SFAS 142 impairment testing purposes you
evaluate
approximately 20 reporting units.  Considering that you identify
only
four, and soon to be three, reportable segments for SFAS 131
purposes
it appears that you are aggregating numerous reporting units for
segment reporting purposes.  Please tell us further detail about
each
of the aggregated segments and the bases for the aggregation.
Fully
show us that you have appropriately applied the aggregation
criteria
from SFAS 131.

4. As a related matter, to help us understand your segment
analysis
under SFAS 131 please tell us about how your business is organized
and managed.  Describe the direct reports reviewed by your Chief
Operating Decision Maker/s (CODM), as well as the next level below
the direct reports.  Tell us about the significant components of
the
reports reviewed by CODM(s) and clarify the nature of the
information
reviewed, including how that information is organized.  Your
response
should show us that you have appropriately identified reportable
segments under SFAS 131.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please file your cover
letter
on EDGAR.  Please understand that we may have additional comments
after reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Praveen Kartholy at (202) 551-3778 or me at
(202) 551-3605 if you have questions regarding these comments.  In
this regard, do not hesitate to contact Brian Cascio, Accounting
Branch Chief, at (202) 551-3676.

							           Sincerely,



							           Gary Todd
					             	           Reviewing
Accountant

William Jellison
Dentsply International Inc.
April 25, 2006
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