SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 November 8, 2019

Via E-Mail

David Aboudi
Aboudi Legal Group PLLC
745 Fifth Ave., Suite 500
New York, NY 10151

Re: Document Security Systems, Inc.
PRE N14A filed on November 5, 2019
DFAN14A filed November 5, 2019
DFAN14A filed October 20, 2019
File No. 1 -32146

Dear Mr . Aboudi :

The staff in the Office of Mergers and Acquisitions in the Division of Corporation
Finance has conducted a limited review of the filings  listed above  and have the following
comments. In some of our comments, we may ask you to provide us with information so we may
better understand your disclosure.

Please respond to this letter by revisi ng your proxy statement , by providing the requested
information, o r by advising us when you will provide the requested response. If you do not
believe our comments apply to your facts and circumstances or do not believe an amendment is
appropriate, please tell us why in your response.

After reviewing your revised preliminary proxy statement and any information you
provide in response to these comments, we may have additional comments.   All defined terms
used here have the same meaning as in your proxy statement, unless otherwise indicated.

Preliminary Proxy Statement filed on Nove mber 5, 2019

1. Since this is a contested solicitation involving a director election contest, the correct
EDGAR “tag” is PREC14A.  Please revise in your next filing of the amended preliminary
proxy statement.

2. Please fill in the blanks throughout the proxy statement.  Information subject to change
may be bracketed.

David Aboudi , Esq.
Aboudi Legal Group PLLC
November 8, 2019
Page 2

Background of the Solicitation

3. Explain why Mr. Feigenbaum decided not become a consultant to the Company.
Specifically, explain why he did  not believe this wou ld provide value to the Company.

4. Provide more details about the contacts between Mr. Feigenbaum and Mr. Chan
referenced in paragraph 3 in this section. Specifically, what “other ventures ” were
discussed and  what role for the participants in this solicitation was contemplated?   See
Item 5 of Schedul e 14A.

5. In paragraph  4 of this section, describe the alternatives discussed to increase shareholder
value.   Describe the “concrete proposal s” Mr. Feigenbaum made to Mr. Chan and
describe the reaction (if any).

Reasons for the Solicitation

6. Here or where appro priate in the proxy statement, please describe  your nominees ’ plans
for changes at DSS if they are elected to the board, either as a minority or if you are able
to accomplish a change in con trol by winni ng a majority of  the seven seat up for election.
Please be as specific as po ssible.

Proposal 1.  Election of Directors

7. Identify the “public ly-traded  companie s” for which Mr. Feigenbaum served as CEO.

8. Identify the organization (s) or entity (ies) for which Mr. Giles Hunt worked and in which
capacity, he “advised clients on acquisitions and capital raising efforts. ”  Provide dates as
appropriate.

9. Clarify the positions at each applicable entity or organization  held by Ms. Kerri Rupert
Schiller over the last five years.  Currently your disclosure includes vague descriptions
that do not make this information clear.

Form of Proxy
10. Refer to Proposal 2 on the form of proxy included  with your proxy statement. Revise to
include  a means by which shareholders may vo te on this proposal to comply with Rule
14a-4(b)(1).

David Aboudi , Esq.
Aboudi Legal Group PLLC
November 8, 2019
Page 3

 We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments,  action or absence of action by the staff .

Please direct any questions to me at (202) 551 -3263 .

        Sincerely,

        /s/ Christina Chalk

Christina Chalk
Senior Special Counsel
Office of Mergers and Acquisitions