From time to time, general dentists who are not adequately trained in a dental specialty are holding themselves out to potential patients as specialists in a particular area of dentistry.  This sort of promotional practice is misleading and does a disservice to patients who are seeking the most qualified dentist to treat their conditions.  Accordingly, I will respectfully submit that it is the obligation of the State Boards of Dentistry that are charged with protecting the interests of dental patients to regulate and prevent this practice. While the prospect of litigation under the First Amendment may tempt some Boards to rely on general prohibitions against deceptive practices rather than promulgate regulations that specifically address the issue, I again submit that specific regulation is the preferable course.  Such regulation will provide guidance to practitioners, give the Board explicit criteria to apply in evaluating dental specialty claims, and help to assure that the Board’s regulation will prevail against First Amendment challenges. I strongly encourage that this board NOT make this amendment to the current regulatory policy on specialty advertising. Thank-you.