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Document Security Systems, Inc.

200 Canal View Boulevard, Suite 300

Rochester, NY 14623

 

February 11, 2020

 

Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549

 

Attention: Ms. Sherry Haywood
  Mr. Edward Kelly

 

  Re: Document Security Systems, Inc.
    Registration Statement on Form S-1
    Filed January 24, 2020
    File No. 333-236082

 

Ladies and Gentlemen:

 

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Document Security Systems, Inc. (the “Company”) hereby requests acceleration of the effectiveness of the above-referenced Registration Statement so that such Registration Statement will become effective as of 4:00 p.m. Eastern time, Wednesday, February 12, 2020, or as soon thereafter as practicable, or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission.

 

  Very truly yours,
   
  DOCUMENT SECURITY SYSTEMS, INC.
   
  By: /s/ Frank D. Heuszel
    Frank D. Heuszel
    Chief Executive Officer and
    Interim Chief Financial Officer