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

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

October 28, 2005

VIA EDGAR AND FEDERAL EXPRESS
-----------------------------

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

         Attn:    Jeffrey Riedler, Assistant Director
                  Division of Corporation Finance

                  Albert Lee, Esq.

         Re:      Applied DNA Sciences, Inc.
                  Amendment No. 3 to Registration Statement on Form SB-2
                  File No. 333-122848
                  Amended Registration Statement filed August 29, 2005

Ladies and Gentlemen:

     The following  responses address the comments of the reviewing Staff of the
Commission  as set forth in a  comment  letter  dated  September  12,  2005 (the
"Comment Letter")  relating to Amendment No. 3 to the Registration  Statement on
Form SB-2 (the  "Registration  Statement")  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.  4 to the  Company's  Registration
Statement.

FORM SB-2
---------

General
-------

1.   We note that on pages 19 and 20 of your  SB-2,  Amendment  No. 3, you state
     that you have entered into a licensing  agreement  with Biowell  Technology
     Inc.  pursuant to which  Biowell is required to pay you a royalty of 10% on
     all net sales and is required to meet certain  minimum  annual net sales in
     various  territories,  including Iran and Syria.  In light of the fact that
     Iran and Syria have been  identified by the U.S. State  Department as state
     sponsors of terrorism and are subject to economic sanctions administered by
     the U.S.  Treasury  Department's  Office of Foreign Assets Control,  please
     describe for us the extent of your  current  and/or  anticipated  contacts,
     directly or indirectly,  including through licensees,  with Iran and Syria,
     and entities in Iran and Syria;  the  materiality  to you of your  contacts
     with  Iran  and  Syria;  and  your  view  as  to  whether  those  contacts,
     individually or in the aggregate, constitute a material investment risk for

<PAGE>
Securities and Exchange Commission
October 28, 2005
Page 2 of 17

     your security  holders.  In preparing  your response  please  consider that
     evaluations  of  materiality  should  not be based  solely on  quantitative
     factors,  but should include  consideration  of all factors,  including the
     potential  impact of corporate  activities upon a company's  reputation and
     share value,  that a reasonable  investor would deem important in making an
     investment  decision.  In this regard,  we note that legislation  requiring
     divestment  from, or reporting of interests in,  companies that do business
     with countries  designated as state sponsors of terrorism has recently been
     adopted by Arizona and Louisiana.

     Response
     --------

     There are no past, current or intended,  communications,  personal contacts
     or contracts,  directly or indirectly,  of any nature whatsoever  including
     through licensees or  intermediaries,  with Iran and/or Syria,  and/or with
     entities  in Iran  and  Syria.  This  situation  applies  to  both  Biowell
     Technologies  Inc and to  Applied  DNA  Sciences,  Inc.  Thirty  three (33)
     countries  were  listed  in the  license  agreement.  Iran and  Syria  were
     included  simply as part of the  process  to compile a list  including  all
     countries in the geographical  territories  licensed to Biowell Technology,
     Inc. The license  agreement was composed to cover all countries in Asia and
     the Middle East. We are presently  will at all times in the future be fully
     compliant   with  all  US  Government   regulations   dealing  with  export
     restrictions.  We  have  subsequently  amended  the  license  agreement  to
     indicate  that  any  country  that has been  identified  by the U.S.  State
     Department  as state  sponsors  of  terrorism  or are  subject to  economic
     sanctions  administered by the U.S. Treasury Department's Office of Foreign
     Assets  Control,  or are in any other way  proscribed by the United States,
     will not be a territory under the license agreement until such time as that
     country has been removed  from such list of state  sponsors of terrorism or
     any other restricted list and are not subject to economic  sanctions by the
     U.S. Treasury  Department's Office of Foreign Assets Control. We have filed
     such  amendment  as an exhibit  and we have  revised  our  language  in the
     registration statement to reflect this.

2.   Prior to requesting acceleration for effectiveness,  please amend your Form
     10-KSB for the year ended  September 30, 2004 and your Forms 10-QSB for the
     quarters  ended  December  31, 2004,  March 31, 2005 and June 30, 2005,  as
     applicable, to comply with our comments on your Form SB-2.

     Response
     --------

     Prior to requesting acceleration for effectiveness,  we will amend our Form
     10-KSB for the year  ended  September  30,  2004 and our Forms 10-Q for the
     quarters  ended  December  31, 2004,  March 31, 2005 and June 30, 2005,  as
     applicable, to comply with your comments on our Form SB-2.
<PAGE>
Securities and Exchange Commission
October 28, 2005
Page 3 of 17

Cover Page
----------

3.   You have  registered  a total of  45,995,326  shares  of  common  stock for
     resale,  however your introductory paragraph refers to more than 55 million
     shares. Please advise or revise.

     Response
     --------

     We have revised our  introductory  paragraph to indicate that the number of
     shares of common stock  issuable upon the exercise of common stock purchase
     warrants is 20,367,000, not 30,367,000.

Overview, page 23
-----------------

4.   Please file as exhibits the agreements with Holomex, and the Departments of
     Energy, Agriculture and Defense.

     Response
     --------

     We are filing  herewith the  agreements  with Holomex and the Department of
     Energy.  Our research  agreement  with the  Department of  Agriculture  has
     expired and there is no written  agreement  with the Department of Defense.
     We have amended the  disclosure  throughout the  registration  statement to
     remove any  reference  to  agreements  with the  Departments  of Defense or
     Agriculture.

5.   Additionally  for each of these  agreements,  please  describe the material
     provisions of these  agreements in the Business  section.  Your  discussion
     should include:

          -    All  material  rights  and  obligations  of  the  parties  to the
               agreement;
          -    Duration of the agreement;
          -    Payment terms;
          -    Termination   provisions,   including   consequences   of   early
               termination; and
          -    Any other terms that may be considered material.

     If you believe the agreements  are made in the ordinary  course of business
     and does not need to be filed as exhibits,  supplementally,  please provide
     your analysis explaining why you believe the agreements are immaterial.
<PAGE>
Securities and Exchange Commission
October 28, 2005
Page 4 of 17

     Response
     --------

     We have revised our  disclosure  in the  Business  section to provide for a
     description of our agreements with Holomex and the Department of Energy and
     to describe all material terms of these agreements.

Product Research and Development
--------------------------------

Textiles, page 33
-----------------

6.   Please  provide us  supplementally  with a copy of the Department of Energy
     report.  We may have additional  comments.  In addition,  please expand the
     discussion to indicate when the report was prepared and released.

     Response
     --------

     We are providing to you, on a supplemental  basis, a copy of the Department
     of Energy report.  We have further  revised our disclosure to indicate that
     the report was prepared on June 1, 2005 and the final  version was provided
     to us on June 9, 2005.

7.   Please  expand  the  discussion  to  indicate  the  extent to which you are
     compensated  for the expenses  incurred for the treated  threads and labels
     you refer to in your discussion.

     Response
     --------

     We have  revised our  disclosure  to indicate  that we provided  the sewing
     thread and labels and that the cost for these items was nominal.

8.   Please expand the  discussion to explain what you mean by "obtaining  final
     product  liability  underwriter   approval,"  when  you  applied  for  such
     coverage,  the amount of coverage,  and when you anticipate marketing these
     products to consumers.

     Response
     --------

     We have revised our disclosure to indicate that the tests  conducted by the
     Department of Energy have demonstrated that DNA coated onto various threads
     can be  recovered  in a  laboratory  setting,  and is a feasible way to add
     DNA-based  security  to textile  products.  As the tests  conducted  by the
     Department  of Energy have  assured us that DNA can be reliably  recovered,
     and results are satisfactory to both us and Champion Thread,  we are in the
     process  of  obtaining  product  liability  insurance  and will  anticipate
     marketing these products to consumers shortly thereafter.
<PAGE>
Securities and Exchange Commission
October 28, 2005
Page 5 of 17

Inks/coatings, page 33
----------------------

9.   We note your reference to "a ten-fold speed improvement." Have you achieved
     this increase in speed,  when did you achieve this  increase,  and for whom
     was the  demonstration?  If you have not achieved the increase in speed, to
     what extent have you improved  the speed and why was the ten-fold  increase
     deemed necessary for prototype kits?

     Response
     --------

     We have revised our disclosure to indicate that  conventional  PCR can take
     approximately four to five hours to detect and verify DNA. Our commercially
     available machine, the Real-Time PCR, can detect the presence of DNA in the
     matter of a half-hour. In the test conducted by the Department of Energy, a
     comparison was made between  conventional PCR and our RT-PCR,  which showed
     that by choosing our RT-PCR, the time-to-result duration can be improved 10
     fold. This information can be seen in the report we have provided to you on
     a supplemental basis.

Substrates/holograms, page 34
-----------------------------

10.  Please update your discussion  relative to your test results.  In addition,
     please expand the discussion to clarify the  relationship  of your research
     with hot stamp varnish and the  Department of Energy.  Is the Department of
     Energy paying you for this research or otherwise  compensating  you? Is the
     Department of Energy conducting the tests?

     Response
     --------

     We have revised our  disclosure  to indicate that test results show that by
     using RT-PCR and proper extraction protocol,  DNA can be recovered from hot
     stamp varnish on the hologram.  We have  submitted the DNA  concentrate  to
     Holomex  for  formulation  of the hot stamp  application.  We have  further
     revised our  disclosure to indicate that pursuant to our agreement with the
     Department of Energy,  they perform validation tests under our CRADA and we
     pay for all testing services.

11.  Please  expand  the   discussion  to  clarify  and  describe  the  specific
     relationship  with  the  Department  of  Agriculture.  Who will pay for the
     services of the Agriculture Research Service lab?

     Response
     --------

     As discussed above,  our CRADA with the Department of Agriculture  expired;
     therefore, we have removed all references to an agreement with them.
<PAGE>
Securities and Exchange Commission
October 28, 2005
Page 6 of 17

12.  Please expand the discussion  concerning the Oak Ridge National  Laboratory
     demonstration  to  describe  the  nature  of the  demonstration,  when  the
     demonstration will occur, how many other technologies  and/or companies are
     competing  with you,  and the extent you which you will be  reimbursed  for
     your presentation.

     Response
     --------

     We have  revised our  disclosure  to discuss as much as we are aware of the
     nature of the demonstration. The disclosure we make is as follows:

     The  Department of Energy was  developing  an  initiative  to identify,  or
     develop marker systems to defeat counterfeiting of textile goods. Oak Ridge
     National  Laboratory  was to manage the  project  and the  funding  for the
     Department of Energy. We are only aware of the competitive  technologies of
     nano-barcodes and another non-specific low energy nuclear marker. Oak Ridge
     National Laboratory cannot provide details of these technologies to us. Oak
     Ridge National  Laboratory was to evaluate these two technologies,  and our
     DNA solution;  once finally developed fully, which requires a reader system
     to make it a complete  solution.  Since the  Department  of Energy is still
     addressing  this  development  work,  we have not  submitted the DNA marker
     technology to Oak Ridge National Laboratory for evaluation.  Any submission
     we make in connection with this program will be done at our own expense. We
     have other concerns that Oak Ridge National  Laboratory may be developing a
     marker on their own, with another industry partner. If this turns out to be
     the case,  it is not  likely we will  participate  in the ORNL  evaluation.
     However, we maintain the possibility of future collaborative  opportunities
     to develop a solution  for a  particular  industry  application,  where the
     Idaho  National  Lab and Oak  Ridge  National  Laboratory  can  assist  us,
     possibly under separate agreements.

Consolidated Financial Statements
---------------------------------

Statements of Losses, page F-3
------------------------------

13.  We  acknowledge  your  response to comment 8 per our letter  dated June 27,
     2005. We continue to believe that, according to paragraphs 11 (c) and 13 of
     SFAS No.  2,  the  license  fee paid to  Biowell  Technology  represents  a
     research and development  cost and should be separately  classified on your
     statements of  operations.  In  particular,  we reference your statement on
     page F-32,  which seems to indicate that the license is the  foundation for
     your further development of products, as opposed to your assertion that the
     license  related to the  marketing  of existing  Biowell  products.  Please
     revise your statements of operations for all affected periods  accordingly,
     or provide us with additional information to support your classification of
     this license fee within selling, general and administrative expense.
<PAGE>
Securities and Exchange Commission
October 28, 2005
Page 7 of 17

     Response
     --------

     We  acknowledge  the payments made in connection  with the Biowell  license
     represent   research  and  development   expenditures.   Our  research  and
     development  footnote to financial statements have been revised to disclose
     research and development costs, including the license fees paid to Biowell

     The Company accounts for research and development  costs in accordance with
     the  Financial   Ac