UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                              WASHINGTON, D.C. 20549


     DIVISION OF
CORPORATION FINANCE


                                                              November 7, 2019

  Via E-Mail

  Jay Yamamoto
  Sichenzia Ross Ference LLP
  1185 Avenue of the Americas
  New York, NY 10036

          Re:     Document Security Systems, Inc.
                  PRE 14A filed on November 4, 2019
                  File No. 1-32146

  Dear Mr. Yamamoto:

          The staff in the Office of Mergers and Acquisitions in the Division
of Corporation
  Finance has conducted a limited review of the filing listed above 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 this letter by revising your proxy statement, by
providing the requested
  information, or by advising us when you will provide the requested response.
If you do not
  believe our comments apply to your facts and circumstances or do not believe
an amendment is
  appropriate, please tell us why in your response.

         After reviewing any amendment to your filing and the information you
provide in
  response to these comments, we may have additional comments. All defined
terms used here
  have the same meaning as in your proxy statement, unless otherwise indicated.

  Preliminary Proxy Statement filed on November 4, 2019

      1. Since this is a contested solicitation involving a director election
contest, the correct
         EDGAR "tag" is PREC14A. Please revise in your next filing of the
amended preliminary
         proxy statement.

      2. Please mark the proxy statement as preliminary. See Rule 14a-6(e)(1).

      3. Please fill in the blanks throughout the proxy statement. Information
subject to change
         may be bracketed.

      4. Include a background section detailing the events and contacts with
the dissidents leading
         up to this contest.
 Jay Yamamoto, Esq.
Sichenzia Ross Ference LLP
November 7, 2019
Page 2

Transactions with Related Persons

   5. We note the disclosure that days before the record date for this annual
meeting, the
      Company sold 6,000,000 additional shares to the Chairman of the Board,
Fei Hang Chan.
      To present this sale in context, disclose the percentage increase in Mr.
Chan's holdings as
      a result of the November 1, 2019 purchase.

Proposal 1. Election of Directors

   6. For each of the nominees, provide dates for the positions listed that
they have held over
      the last five years.

Form of Proxy

   7. Please file a form of proxy card (marked preliminary) with your revised
preliminary
      proxy statement.

       We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

       Please direct any questions to me at (202) 551-3263.


                                                            Sincerely,


                                                            /s/ Christina Chalk


                                                            Christina Chalk
                                                            Senior Special
Counsel
                                                            Office of Mergers
and Acquisitions