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                            June 3, 2020

       Frank D. Heuszel
       Chief Executive Officer and Interim Chief Financial Officer
       Document Security Systems, Inc.
       200 Canal View Boulevard, Suite 104
       Rochester, NY 14623

                                                        Re: Document Security
Systems, Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed May 21 2020
                                                            File No. 333-238587

       Dear Mr. Heuszel:

              We have limited our review of your registration statement to
those issues that we have
       addressed in our comment. In our comment we may ask you to provide us
information so that
       we may better understand your disclosure.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe that our comment applies to
your facts and
       circumstances or do not believe that an amendment is appropriate, please
tell us why in your
       response.

              After reviewing any amendment to your registration statement and
the information that
       you provide in response to the comment, we may have additional comments.

       Registration Statement on Form S-1 filed May 21, 2020

       General

   1.                                                   We note your recent
acquisition of AMRE Asset Management Inc. and your planned
                                                        transaction with Impact
BioMedical Inc. Please tell us your consideration of providing
                                                        financial statements of
these businesses and pro forma information reflecting the
                                                        transactions in this
filing pursuant to Rules 8-04 and 8-05 of Regulation S-X.
               We remind you that the company and its management are
responsible for the accuracy
       and adequacy of their disclosures, notwithstanding any review, comments,
action, or absence of
       action by the staff.

              Refer to Rules 460 and 461 regarding requests for acceleration.
Please allow adequate
       time for us to review any amendment before the requested effective date
of the registration
 Frank D. Heuszel
Document Security Systems, Inc.
June 3, 2020
Page 2

statement.

        Please contact Edward M. Kelly, Senior Counsel, at (202) 551-3728 or
Asia Timmons-
Pierce, Special Counsel, at (202) 551-3754 with any questions.



FirstName LastNameFrank D. Heuszel                       Sincerely,
Comapany NameDocument Security Systems, Inc.
                                                         Division of
Corporation Finance
June 3, 2020 Page 2                                      Office of
Manufacturing
FirstName LastName