December 3, 2018

Ping Rawson
Chief Accounting Officer
Dyadic International, Inc.
140 Intracoastal Pointe Drive, Suite 404
Jupiter, Florida 33477

       Re: Dyadic International, Inc.
           Form 10-12G
           Filed November 5, 2018
           File No. 000-55264

Dear Mr. Rawson:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

     After reviewing your response and any amendment you may file in response
to these
comments, we may have additional comments.

Registration Statement on Form 10-12(g) filed November 5, 2018

Other Market Opportunities, page 9

1.     Please identify the parties with whom you have entered into the two
funded proof of
       concept research collaborations and file the agreements as exhibits.
Risks Related to the Potential Reverse Stock Split..., page 27

2.     Please disclose the range of the reverse stock split ratios that your
shareholders approved
       and disclose any other material provisions of the stock split.
Item 13. Financial Statements and Supplementary Data, page 60

3.     Please update the disclosures and financial statements in order to
comply with Rule 8-08
       of Regulation S-X.
 Ping Rawson
Dyadic International, Inc.
December 3, 2018
Page 2
General

4.       Please be advised that your registration statement will automatically
become effective 60
         days after the initial filing date. Upon effectiveness, you will
become subject to the
         reporting requirements of the Securities Exchange Act of 1934, even if
we have not
         cleared comments. If you do not wish to incur those obligations until
you have cleared
         comments, you may wish to consider withdrawing your registration
statement before it
         becomes effective automatically and submitting a new registration
statement when you
         respond to our comments.
5.       We note that your forum selection provision identifies the Court of
Chancery of the State
         of Delaware as the exclusive forum for certain litigation, including
any "derivative
         action." Please disclose whether this provision applies to actions
arising under the
         Securities Act or Exchange Act. In that regard, we note that Section
27 of the Exchange
         Act creates exclusive federal jurisdiction over all suits brought to
enforce any duty or
         liability created by the Exchange Act or the rules and regulations
thereunder. If this
         provision does not apply to actions arising under the Securities Act
or Exchange Act,
         please also ensure that the exclusive forum provision in the governing
documents states
         this clearly.
        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.

        You may contact Mindy Hooker (Staff Accountant) at 202-551-3728 or John
Cash (Accounting Branch Chief) at 202-551-3768 if you have questions regarding
comments on
the financial statements and related matters. Please contact Edward Kelly
(Staff Attorney) at
202-551-3728 or Asia Timmons-Pierce (Special Counsel) at 202-551-3754 with any
other
questions.



                                                              Sincerely,
FirstName LastNamePing Rawson
                                                              Division of
Corporation Finance
Comapany NameDyadic International, Inc.
                                                              Office of
Manufacturing and
December 3, 2018 Page 2                                       Construction
FirstName LastName