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August 28, 2007
  Mr. James Hayward Chief Executive Officer Applied DNA Sciences, Inc.  25 Health Sciences Drive, Suite 113 Stony Brook, NY 10532
Re: Applied DNA Sciences, Inc.
 Amendment No. 8 to Registrati on Statement on Form SB-2
  Filed November 13, 2006   File No. 333-122848

Dear Mr. Hayward:
We have reviewed your filings and most re cent response letter furnished via EDGAR on
July 5, 2007 and have the following comments.  Where indicated, we think you should revise
your documents in response to these comment s.  If you disagree, we will consider your
explanation as to why our comment is inapplicab le or a revision is unnecessary.  Please be as
detailed as necessary in your e xplanation.  In some of our comme nts, we may ask you to provide
us with supplemental information so we may be tter understand your disclosure.  After reviewing
this information, we may or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements and to enhance the overall disclosure in
your filing.  We look forward to working with you in these respects.  We welcome any questions
you may have about our comments or on any other aspe ct of our review.  Feel free to call us at
the telephone numbers listed at  the end of this letter.

Amendment No. 8 to Registration Statement on Form SB-2

General
 1. Prior to requesting acceleration for effectiv eness, please refer to Item 310(g) of
Regulation S-B and amend your registration statement on Form SB-2 to provide updated
audited financial statements for the year s ended September 30, 2006 and 2005, as well as

Mr. James Hayward
Applied DNA Sciences, Inc.
August 28, 2007
Page 2

unaudited interim financial statements and re lated information for the period ended June
30, 2007.
 Notes to Condensed Consolidated Financial Information

 Note I – Restatement of Quarterly Financial Statements, page F-45

 1. We acknowledge your proposed revisions in response to comment 2 as well as the
supplemental tabular restatement information that you have presented for the three and
nine months ended June 30, 2006 and for th e period from inception through June 30,
2006. Please provide us with the clarifying in formation that follows and revise the
disclosure in your filing accordingly.
• It remains unclear based on the info rmation provided how you calculated the
$5,838,514 adjustment to selling, general and administrative expense. Per page 29
of your May 1, 2007 response letter, it appear s that the sel ling, general and
administrative adjustment is $8,051,565, not $6,402,264. Please clarify for us how you derived the $5,838,514.

• Similarly, please clarify how you de termined the $4,117,500 portion of the
September 30, 2005 restatement adjustment to interest expense in deriving the
$10,058,055 adjustment for the cumulative period ended June 30, 2006.  In addition, your discussion in your respons e to comment 7d on page 34 states that
the $4,117,500 was charged to consulting fees, not interest expense.
 Note J- Restatement of June 30, 2005 Quar terly Financial Statements, page F-48

 2. We acknowledge your response to comment 4 and reissue our comment. Please confirm
that you will timely amend your June 30, 2007 Form 10-QSB to reflect the revised
restatement information that you ultimately pr esent in your Form SB-2 at the conclusion
of our related comment process.
 Notes to (Audited) Consolidated Financial Statements (Restated)

 Note M – Restatement of Financial Statements, page F-91

 3. Please confirm that you will timely amend your September 30, 2006 Form 10-KSB to
reflect the revised restatement information that  you ultimately present in your Form SB-2
at the conclusion of our related comment process.

* * * * *
   As appropriate, please amend your filings in response to these comments.  You may wish
to provide us with marked copies of the amendm ents to expedite our review.  Please furnish a

Mr. James Hayward
Applied DNA Sciences, Inc.
August 28, 2007
Page 3

cover letter with your amendments that keys your responses to our comments and provides any
requested supplemental information.  Detailed cove r letters greatly facilita te our review.  Please
understand that we may have additional comm ents after reviewing your amendments and
responses to our comments.   We direct your attention to Rules 460 and 461 regarding requesting acceleration of a
registration statement.  Please a llow adequate time after the fili ng of any amendment for further
review before submitting a request for acceleration.  Please provide this request at least two business days in advance of the requested effective date.
You may contact Amy Bruckner,  Senior Staff Accountant, at (202) 551-3657 or Mary
Mast, Senior Staff Accountant, at (202) 551-3613  if you have questions regarding comments on
the financial statements and related matters.  Pl ease contact John Krug, Seni or Staff Attorney, at
(202) 551-3682 or me at (202) 551- 3715 with any other questions.

 Sincerely,

Jeffrey P. Riedler
        A s s i s t a n t  D i r e c t o r     cc: Joe Daniels, Esq.
Fulbright & Jaworski LLP
666 Fifth Avenue, 31
st Floor
New York, NY 10103-3198