February 7, 2019

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

       Re: Dyadic International, Inc.
           Registration Statement on Form 10
           Filed January 14, 2019
           File No. 0-55264

Dear Ms. Rawson:

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

       Please respond to these comments within 10 business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe that
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 filed January 14, 2019

Exclusive Forum Provision, page 60

1.     We note your response to comment 5 of our letter dated December 3, 2018
and reissue our
       comment. 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 under it, and
       Section 22 of the Securities Act creates concurrent jurisdiction for
federal and state courts
       over all suits brought to enforce any duty or liability created by the
Securities Act or the
       rules and regulations under it. If this provision does not apply to
actions arising under the
       Securities Act or Exchange Act, please ensure that the exclusive forum
provision in the
 Ping H. Rawson
Dyadic International, Inc.
February 7, 2019
Page 2
         governing documents states this clearly. If the provision applies to
Securities Act claims,
         please revise your disclosures to disclose this information and to
state that there is
         uncertainty as to whether a court would enforce such provision, and to
state that
         stockholders will not be deemed to have waived the company's
compliance with the
         federal securities laws and the rules and regulations under it.
        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 Melinda J. Hooker, Staff Accountant, at (202) 551-3732
or W. 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 M. Kelly,
Senior Counsel, at
(202) 551-3728 or Asia Timmons-Pierce, Special Counsel, at (202) 551-3754 with
any other
questions.



                                                               Sincerely,
FirstName LastNamePing H. Rawson
                                                               Division of
Corporation Finance
Comapany NameDyadic International, Inc.
                                                               Office of
Manufacturing and
February 7, 2019 Page 2                                        Construction
FirstName LastName