HART & TRINEN, LLP
                                ATTORNEYS AT LAW
                             1624 Washington Street
                                Denver, CO 80203
William T. Hart, P.C.              ________           Email:  harttrinen@aol.com
Donald T. Trinen                                      Facsimile:  (303) 839-5414
                                  (303) 839-0061
--

Will Hart
                               September 27, 2011


Ajay Koduri
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

      Re:   DNA Brands, Inc.
            Registration Statement on Form S-1
            File No. 333-176001

     This office  represents DNA Brands,  Inc.  Amendment No. 1 to the Company's
Registration  Statement  on Form S-1 has been  filed  with the  Commission.  The
following are the Company's responses to the staff's comments received by letter
dated August 26, 2011.

Comment #
---------

1.    The 31,250,000 shares have been distributed to shareholders of DNA
      Beverage Corporation. The shares are restricted from further transfer
      until December 31, 2011. The exemption provided by Section 4 (1) of the
      Securities Act of 1933 was relied upon in connection with the
      distribution.

      With respect to Staff Legal Bulletin No. 4, the Company wanted to register
      the distribution but Larry would not allow it.

      With respect to Compliance Disclosure & Interpretation 612.15, we have
      addressed this matter in our letter to you dated May 26, 2011. However,
      more importantly, CDI 612.15 suffers from a fatal flaw.

      One of the first principles a student learns in law school is there are
      the facts and there is the law. You apply the facts to the law, or vice
      versa, and arrive at a legal conclusion. CDI 612.15 discusses the facts in
      the first paragraph and some sort of legal conclusion in the second
      paragraph. However what is missing is the law which is relied upon to
      reach the conclusion. CDI 612.15 cites no statute or case law in support
      of its position. In this regard, we do not consider staff interpretations
      or the "Worm letter" to be sufficient legal authority which would support
      the conclusion stated in the second paragraph of CDI 612.15






     If you should have any questions  concerning the  foregoing,  please do not
hesitate to contact the undersigned.

                                    Very Truly Yours,

                                    HART & TRINEN, L.L.P.


                                    /s/ William Hart

                                    William T. Hart