United States securities and exchange commission logo June 1, 2021 Frank D. Heuszel Chief Executive Officer Document Security Systems, Inc. 6 Framark Drive Victor, New York 14564 Re: Document Security Systems, Inc. Form S-3 Filed May 24, 2021 File No. 333-256446 Dear Mr. Heuszel: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing