June 30, 2006 - Via Edgar

Mr. Gary Todd
Reviewing Accountant
Division of Corporation Finance
Securities and Exchange Commission
Washington, DC 20549-0306

         Re:      DENTSPLY International, Inc.
                  Form 10-K for the fiscal year ended December 31, 2005 Filed
                  March 14, 2006
                  File No. 000-16211
                  Supplemental response dated June 15, 2006

Dear Mr. Todd:

By letter dated June 15, 2006, the Staff has requested additional information
from DENTSPLY International, Inc. related to the Form 10-K filing and the
supplemental response referenced above. We have set forth below our responses to
the Staff's comments. We have keyed our responses to the Staff's comments by
providing our response immediately following a reiteration of the original Staff
comment. Pursuant to 17 C.F.R. Sec 200.83 confidential treatment of Attachment I
to this letter is requested.

In addition, as requested by the Staff, DENTSPLY International, Inc.
acknowledges that:

o        DENTSPLY International, Inc. is responsible for the adequacy and
         accuracy of the disclosure in the
         filings;
o        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
o        DENTSPLY International, Inc. 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.

Please contact me at 717-849-4243 or at the address below with any additional
comments you have related to subject filings.

Sincerely,

/s/ William R. Jellison

William R. Jellison
DENTSPLY International, Inc.
Sr. Vice President and CFO
221 W. Philadelphia Street
York, PA 17405-0872
(717) 849-4243



COMMENTS AND RESPONSES


Form 10-K for the Fiscal Year Ended December 31, 2005
Item 8. Financial Statements and Supplementary Data


Note 4. Segment and Geographic Information, page 61

1.      We note your response that your reporting units are components of the
        three operating segments that are not operating segments in and of
        themselves.  Under paragraph 10 of SFAS 131 your reporting units appear
        to have characteristics of operating segments in that they a) engage in
        business activities from which they earn revenues and incur expenses,
        b) have operating results that are reviewed by the CODM as their
        financial and non financial measures are included in the reports
        provided to the CODM, and c) have discreet financial information
        available.  Furthermore, paragraph 12 of SFAS 131 states that a CODM
        identifies a function, not necessarily a manager.  That function is to
        allocate resources to and assess the performance of the segments, which
        can be done by one person or a group of persons.  Please further explain
        why your segment disclosure is appropriate under SFAS 131.  In that
        regard, please address the following:

o        Tell us why the group consisting of the President/Chief Operating
         Officer and the Senior Vice Presidents does not constitute the CODM
         role for SFAS 131 purposes.

o        The individual segments appear to aggregate various geographies,
         product categories, and divisions. Accordingly it is unclear how you
         assess performance and make resource allocation decisions when the
         individual operating segments include such apparently diversified
         operations. Please more specifically describe how the financial
         packages are reviewed in assessing performance and in arriving at
         resource allocation decisions.

o        Please tell us if there are managers (with a focus on function) at the
         reporting units who report to the Senior Vice Presidents. Refer to
         paragraph 14 of SFAS 131. If so, describe their roles and
         responsibilities.

o        Provide us a sample of the segment and reporting unit financial
         information regularly provided to the President/Chief Operating
         Officer.

Response:

Dentsply's management structure is organized to hold its Senior Vice President's
(SVP's) accountable for the results of the operating segment for which they are
responsible. While the process is participative, it is not management by
consensus. Only the President and Chief Operating Officer (COO) can make
decisions which direct the operating and policy matters of all three operating
segments, and none of the SVP's have the authority to make, nor do they make,



any decisions with respect to the operating or policy matters of the segments
for which they are not directly responsible. Additionally, the SVP's cannot
obtain additional resources, such as capital expenditures, expense levels and
working capital, for their segment above and beyond those allocated to their
segment by the COO, without the approval of the COO.

The Company has three operating segments which are managed by three SVP's, with
each segment being managed as a business portfolio. These business portfolio's
are comprised of reporting units that were combined taking into consideration a
number of factors including, reporting units that operate in the same product or
geographic markets, reporting units that have significant interdependencies on
other reporting units within the same operating segment, or where the COO
believes that the highest level of synergies may be achieved as a result of a
single SVP being in charge of multiple reporting units. As acquisitions are
made, the acquired business is incorporated into the business portfolio that
represents the best fit with the current portfolio being managed by each SVP.

While it may appear that each of these operating segments cover a wide range of
product categories and geographic regions, it is important to note that each
segment consists of reporting units that operate almost entirely in the
professional dental market and as a result are similar in many respects. For
example, all of the operating segments except one produce and sell only
professional dental products (professional dental consumables and small dental
equipment). The one exception is a segment that in addition to professional
dental product businesses, has a business that sells products for producing
investment castings in the jewelry and golf club casting industries. This is a
small component of the overall Company, comprising approximately 2.5% of sales
in 2005. Except for this one business mentioned above, essentially all of the
other operations of the Company are engaged solely in the production and sale of
professional dental products. In total, professional dental products represented
approximately 97.5%, 98% and 98% of sales in 2005, 2004 and 2003, respectively

Additionally, for many of the reporting units, the production processes are
similar in many respects. The dental consumables are generally produced in small
batch operations, and many of the small dental equipment products involve
assembly type operations.

Another similarity involves the methods of distribution. The sale and
distribution of a product may vary by product and by region, but is either a
direct sale by the Company's own sales force or a sale through a dental
distributor. Products are sold either direct or through distributors depending
on the region of the world. A product sold direct in the United States may be,
and many times is, sold through distributors in other parts of the world. Each
operating segment has both direct and distributed sales.

It is these similarities that provide an overriding tone for each segment and
that provides the basis for the COO to assess the performance of and make
decisions for resource allocation to each operating segment. The processes by
which the performance of each operating segment is assessed and the decisions
for resource allocation are described in additional detail below.



In the third quarter of each calendar year, the SVP's are responsible for
overseeing the preparation of annual budgets for the reporting units under their
leadership. Once approved by the SVP's the annual budgets are presented
separately by each SVP and the respective operating segment Controller (who is
responsible for the accounting and financial reporting of their operating
segment) to Corporate management which generally includes the Chief Executive
Officer (CEO), COO, Chief Financial Officer (CFO), and other Corporate Vice
Presidents. The SVP's for the other segments are not in attendance at any
meetings other than the budget review meetings for their operating segment,
and have no review or approval authority over the reporting units outside of
their segment. Through participation of the attendees at the budget review
meetings, additional changes may be made to operating location and operating
segment budget targets which are the responsibility of the SVP of the segment.
At the completion of the budget process, each segment SVP has a segment budget
which they are responsible for operating within and also has responsibility for
any changes among the reporting units of their segment.

Resources are allocated to each operating segment by the COO during the budget
process and then on an as necessary basis as determined by the COO. The
resources allocated by the COO during these processes can then be allocated to
the reporting units as the SVP sees fit. Examples of these allocations by the
SVP's to the reporting units are capital expenditures, expense levels,
headcount, compensation increases and levels, and working capital levels.

In addition to those resources allocated to the segments specifically by the
COO, broader corporate issues, such as IT systems and regulatory requirements,
are determined at the corporate level and include the involvement of the CEO,
COO, CFO, and various Corporate Vice Presidents and Directors.

Most operating decisions made at the reporting units are made by the reporting
unit's General Manager (GM) with input from the responsible SVP, as required.
There are currently 29 reporting units, each with a GM. The GM of each reporting
unit reports to the SVP of their respective operating segment, and the GM has no
regular contact with the COO. The GM is responsible for the reporting unit's
results and they work directly with the operating segment SVP on a regular basis
on issues regarding operating performance. Functional managers of the reporting
unit report directly to the GM or to a corporate function as in the case of
reporting unit controllers. The SVP of the operating segment assesses each
reporting unit's performance and its contribution to achieving segment targets.
The SVP manages the GM at each reporting unit in order to achieve the overall
performance of the operating segment, not solely on the performance of the
operating location itself. It is important to note that the SVP's do not
participate in the management of the reporting units outside of their group.

Segment operating results are reviewed at regular meetings (called Corporate
Operating Committee meetings) which are attended by the CEO, COO, CFO, SVP's,



other Corporate Vice Presidents and the three operating segment Controllers. The
process at these meetings is participative, but not management by consensus. At
these meetings, the results of the operating segments are presented separately
by the respective SVP of the operating segment. In each of the separate
presentations, the SVP discusses the total operating segment performance
relative to forecast, budget, and prior year. During these presentations,
significant business issues related to a single reporting unit may be discussed,
but the focus of the discussion is on the results of the operating segments. In
addition, projections for the performance of each operating segment for the
current quarter, subsequent quarters, and the full year are presented and
discussed. At the meeting, the COO listens to each SVP's input and the
participative discussion, and makes decisions based on corporate expectations
and each operating segment's performance and projections. Examples are revised
sales targets, expense levels, capital, and working capital levels. The SVP's
use the input from the COO and determine the impact on the reporting units
within their respective operating segment. Reporting unit GM's do not attend the
Corporate Operating Committee meetings. Reporting unit GMs are managed by their
respective SVPs and take direction through direct interaction with their SVP.

Throughout the year, the SVP's interact closely with the reporting units within
their operating segment, regularly visiting each location and determining what
is needed at each operating location to achieve the operating segment's targets.
On occasion, the COO will visit an operating location to help him understand
first hand operating issues, personnel matters, etc. These visits are on an as
required basis and are not regular in nature.

Information on operating performance of the reporting units and operating
segments is made regularly available to the COO, CFO, SVP's, and other Corporate
Vice Presidents and the three operating segment Controllers. This information is
used by the COO to make informed inquiries and in providing direction to each
operating segment SVP, however, this reporting unit information is not used by
the COO to make operating decisions as these decisions are made at the operating
segment level by the SVP, as illustrated above.

Incentive compensation for the SVP's and the three operating segment Controllers
is based primarily on the actual performance compared to budget for the
operating segment for which they are responsible. Incentive compensation for the
CEO, COO, CFO and other Corporate Vice Presidents and Directors is based on the
total Company's actual net income compared to the budgeted net income and on
internal growth targets.

There are three sources of information that are provided to the COO on a regular
basis which are used to make decisions:

     1) SVP Corporate Operating Committee meeting presentations of operating
        segment results.
     2) Actual operating segment results and comparisons against forecast,
        budget, and prior year on a monthly basis.
     3) Quarter operating segment forecast information provided on a monthly
        basis.



We have provided a sample of each of these as Attachment I in response to your
request. This information is generated on a regular basis for the COO from the
Company's financial information systems, which are currently structured to
process and summarize financial information only on the basis of the Company's
operating segments from the underlying reporting units.

Based on the information provided above and the information provided in our
prior response, we believe our segment disclosure is appropriate and in
accordance with SFAS 131. We believe the conclusion that the COO is the CODM of
the Company and that the CODM is not the group consisting of the COO and the
SVP's is consistent with the guidance in paragraph 12 of SFAS 131. We also
believe that using the management approach, our operating segments are evident
from the management structure of our internal organization and how it functions,
consistent with SFAS 131.




ATTACHMENTS

Due to the size of the attachments and a file type which cannot be converted
into EDGAR format, the sample reports which are provided to the COO referenced
above, are being sent under seperate cover as hard copies.