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    Unassociated Document

    December
15, 2010

    Securities
and Exchange Commission

    100 F
Street, NE

    Washington,
D.C. 20549

              Attention:

              Ryan
      Houseal

              Barbara
      C. Jacobs

              Re:

              Document
      Security Systems, Inc. (the “Company”)

              Amendment
      No. 2 to Registration Statement on Form S-3

              Filed
      October 26, 2010

              File
      No. 333-166357

              Form
      10-Q Fiscal Quarter Ended September 30, 2010

              Filed
      November 15, 2010

              File
      No. 1-32146

    Dear
Staff:

    On behalf
of Document Security Systems, Inc., this letter responds to the comments of the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
to the filing of the above-referenced registration statement (the “Filing”),
which was included in your letter dated November 17, 2010 (the “Staff
Letter”).

    In this
letter, we have indicated our response to each of your comments. The numbered
paragraphs of this letter set forth below correspond to the numbered paragraphs
of the Staff Letter. References in the responses to “we,” “our” or “us” mean
Document Security Systems, Inc.

    Amendment No. 2 to
Registration Statement on Form S-3

         Risk
Factors,

    “We have material weaknesses
in our control over financial reporting structure, which until remedied, may
cause errors in our financials” page 11

    1.           We
reissue prior comment 1 in part and ask that you please revise your document to
discuss when you anticipate remediating the material weakness in your internal
control over financial reporting.  You should also discuss when
material weakness in your internal control first began.   As
noted before, please ensure that similar disclosure is included in your Exchange
Act reports.  In this regard, we are unable to locate any such
disclosure in your Form 10-Q for quarter September 30, 2010.

    RESPONSE:

    We will incorporate these
elements into the discussion of our material weakness Risk Factors, including
the expected time of remediation in future Exchange Act
Reports.

    Form 10-Q Fiscal Quarter
Ended September 30, 2010

    Item
6.  Exhibits

         2.                      We
refer to prior comment 4 and note that you continue to replace the word “report”
with “quarterly report” in paragraphs 2 and 3 of the certifications required by
Exchange Act Rule 13a-14(a).  As such, we reissue prior comment 4 and
ask that you confirm that in subsequent filings, the word “report” in these
paragraphs will not be preceded or modified by the period to which the
certification pertains.

    RESPONSE:

    We will exclude the word
“quarterly” or other reference to the period to which the certification pertains
from paragraphs 2 and 3 of the certification required under Exchange Act Rule
13a-14(a) in future Exchange Act Reports.

    Thank you
for your assistance in this matter.  Please feel free to call me at
(585) 325-3610 if you have any questions about this matter.

              Respectfully
      submitted,

              DOCUMENT SECURITY
      SYSTEMS, INC.

                By:

              /s/  Patrick
      White

              Patrick
      White

              Chief
      Executive Officer

              /s/  Philip
      Jones

              Philip
      Jones

              Chief
      Financial Officer