September 6, 2024

Todd D. Macko
Chief Financial Officer
DSS, Inc.
275 Wiregrass Pkwy
West Henrietta, NY 14586

       Re: DSS, Inc.
           Form 10-K for the Year Ended December 31, 2023
           Filed March 27, 2024
           File No. 001-32146
Dear Todd D. Macko:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Year Ended December 31, 2023
Consolidated Statement of Operations, page 37

1.     We note that you have significant impairments and losses on investments,
investments in
       real estate and a provision for loan loss recorded in Other income
(expense). Given that
       you operate businesses that generate investment income, provide loans,
and operate real
       estate businesses, please tell us why you believe these amounts are
appropriately
       classified outside of your operating loss. Additionally, it appears that
the impairments of
       goodwill and intangible assets should be presented as part of operating
loss. Please revise
       future filings accordingly.
Notes to the Audited Financial Statements
Note 2. Summary of Significant Accounting Policies, page 41

2.     We note from your disclosure on page 41 that in May 2023 you distributed
approximately
       280 shares of SHRG in the form of a dividend to the shareholders of DSS
common stock
       and as a result, SHRG was deconsolidated from your consolidated
financial statements.
 September 6, 2024
Page 2

       Please explain to us how you accounted for this transaction within your
statement of
       changes in stockholders    equity including why you increased your
non-controlling interest
       in subsidiary as part of this transaction.
Item 9A - Controls and Procedures
Management's Annual Report on Internal Control over Financial Reporting, page
70

3.     Please revise future filings to include a statement of management   s
responsibility for
       establishing and maintaining adequate internal control over financial
reporting in
       accordance with Item 308(a)(1) of Regulation S-K.
       In closing, 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.

       Please contact Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing