SecProbe.io

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                           Applied DNA Sciences, Inc.
                       9229 W. Sunset Boulevard, Suite 830
                          Los Angeles, California 90069

================================================================================

August 4, 2005

VIA EDGAR AND FEDERAL EXPRESS

Securities and Exchange Commission
100 F Street, N.E.
Washington, DC  20549

         Attn:    Joseph J. Roesler, Senior Accountant
                  Division of Corporation Finance

         Re:      Applied DNA Sciences, Inc.
                  Form 8-K filed July 21, 2005
                  File No. 002-90539

Ladies and Gentlemen:

     The following  responses address the comments of the reviewing Staff of the
Commission  as set forth in a comment  letter dated July 27, 2005 (the  "Comment
Letter")  relating to the Current Report on Form 8-K (the "Form 8-K") of Applied
DNA Sciences,  Inc. (the "Company").  The answers set forth herein refer to each
of the Staffs' comments by number.

     We are filing herewith Amendment No. 1 to the Company's Form 8-K.

FORM 8-K filed July 21, 2005
----------------------------

1.   We  refer  to  Item  4.02  "Non-Reliance  on  Previously  Issued  Financial
     Statement"  of your Form 8-K filed  July 21,  2005.  We have the  following
     comments:

     o    Please disclose the date in which the conclusion was reached regarding
          the non-reliance on previously issued financial statements.

     o    As it appears that  management  reached the  conclusion  regarding the
          non-reliance of previously issued financial statements, please include
          a statement of whether the audit committee,  or the board of directors
          in the  absence  of an  audit  committee,  or  authorized  officer  or
          officers,  discussed  with the company's  independent  accountant  the
          subject matter giving rise to the conclusion.

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Securities and Exchange Commission
August 4, 2005
Page 2 of 2

     Response
     --------

     We have  revised our  disclosure  to  indicate  that on July 11,  2005,  we
     determined  that there were errors in our  accounting  for the valuation of
     equity consulting service  transactions  during the quarter ended March 31,
     2005 and that authorized officers discussed the matter with our independent
     registered public accounting firm.

     The  Company  acknowledges  that:  1) the  Company is  responsible  for the
adequacy  and accuracy of the  disclosure  in the filing;  2) staff  comments or
changes to  disclosure  in  response  to staff  comments  do not  foreclose  the
Commission from taking any action with respect to the filing; and 3) the Company
may not assert staff  comments as a defense in any  proceeding  initiated by the
Commission or any person under the federal securities laws of the United States.

     We trust that the  foregoing  appropriately  addresses the issues raised by
your recent  Letter of Comment.  Thank you in advance for your prompt review and
assistance.

                                Very truly yours,

                              /s/ PETER BROCKLESBY
                                  ----------------
                                  Peter Brocklesby
                                  President

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