SecProbe.io

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 August 22, 2005

 Meagan Caldwell
 Securities and Exchange Commission
 Mail Stop 7010
 Washington, DC 20549-0510

      RE:  Form 10-K for the fiscal year ended December 31, 2004
           Form 10-Q for the period ended March 31, 2005
           File No. 0-17385

 Dear Ms. Caldwell:

      I am writing this letter in response to your comments regarding the
 above listed filings.  We have made amendments to our filings as requested.
 Please see below for explanations to each item.

   1. Where a Comment below requests additional disclosures or other
      revisions to be made, please show us in you supplemental response what
      the revisions will look like.  With the exception of the comments below
      that specifically request an amendment, all other revisions maybe
      included in your future filings.

      Response: Comment noted by Company.

   2. "Please amend your disclosure to include the information relating to
      your principal accountant fees and services.  Please include this
      information in Item 14.  Refer to the instructions to Form 10-KSB."

      Response: Added an Item 14 and disclosed required information
      pertaining to the company's accountant fees and services.

   3. "Please expand your disclosure to discuss the development of your
      business over the past three years.  Refer to Item 101(a) of Regulation
      S-B."

      Response: Added relevant information regarding our business'
      development since 2002.  See Item 1. Business for changes.

   4. "Please expand your disclosure to include the amount you have spent on
      research and development for the years ended December 31, 2004 and
      2003.  Refer to Item 101(b) of Regulation S-B."

      Response:  The amount spent on research and development was a figure of
      minor dollars and did not merit listing.  Please see Item 1. Business
      under Research and Development for our changes.

   5. "Please expand your disclosure to include a discussion of your
      critical accounting estimates.  Refer to SEC Release No. 34-48960."

      Response:  We disclosed the accounting of obsolete inventory, which we
      determine to be material for financial disclosure.

   6. "Please expand your disclosure to discuss the factors that contributed
      to the increase in net sales during the period, including any
      offsetting results these factors may have had with one another.  Please
      include in your discussion factors such as:  a.) licensing agreements
      entered into during the year, including  new agreements entered into,
      terminations of agreements, changes to existing agreements; and b.)
      changes in product mix or volume, including changes to distribution
      channels.  Please also quantify the impact each of these factors had
      on your net sales."

      Response:  We added information regarding new agreements into which we
      entered, terminations of agreements, changes to existing agreements,
      and changes in product mix or volume.  Please see additions under 2004
      versus 2003.

   7. "You disclosed that the increase in gross profit was due to the use of
      obsolete pewter emblems that were previously written down to scrap
      value.  Based on your disclosure in Note 2 regarding items melted down
      during the year and the 14% increase in net sales during the year, it
      would appear that the increase in your gross margins would have been
      greater.  Please expand your disclosure to discuss in more detail the
      factors that contributed to the increase in gross profit during the
      period, including any offsetting results these factors may have had
      with one another.  Please also quantify the impact each of these
      factors had on your gross profits."

      Response:  We added a discussion explaining that the net income was
      offset by the 26% increase in royalty expense.  Please see under 2004
      versus 2003 for changes.

   8. "Please amend your disclosure to include information on your
      disclosure controls and procedures.  Refer to Items 307 and 308 of
      Regulation S-B."

      Response:  A statement was added to address the item 8A Controls and
      Procedures with reference to item 307 of Regulation S-B.  Item 308 of
      Regulation S-B does not apply to the company since we are not an
      accelerated filer.

   9. "Please expand your disclosure to include information regarding your
      audit committee.  Refer to Items 401(e) and (f) of Regulation S-B."

      Response:  We have added a statement expressing that the Company does
      not at this time have an audit committee.

  10. "Please expand your disclosure to discuss whether you have adopted a
      code of ethics.  If you have not, please include in your disclosure the
      reason why you have not done so.  Refer to Item 406 of Regulation S-B."

      Response: We have stated in Item 9. Director and Executive officers of
      the registrant that the company has not adopted a code of ethics at
      this time.

  11. "Your auditor's report does not opine on the consolidated balance
      sheet and the related statements of consolidated operations,
      stockholders' equity, and cash flows for the year ended December 31,
      2003.  Please amend your filing to include audited financial statements
      for the aforementioned period.  If in fact your Form 10-KSB does
      include audited financial statements for the above mentioned period,
      please obtain from your auditors a revised audit opinion, which
      includes this period and file an amended Form 10-KSB.  Refer to Item
      310(a) of Regulation S-B."

      Response:  The auditor's report has been revised to include 2003.

  12. "Please expand your disclosure to discuss how you record fees
      associated with the licensing agreements you enter into.  In your
      disclosure please include the amount and the line item that these
      amounts are recorded in your statements of income for each of the
      periods presented."

      Response: Please see Note 1, under Licensing fees for changes added.

  13. "Please disclose how you account for (a) step rent provisions and
      escalation clauses and (b) capital improvement funding and other lease
      concessions, which may be present in your leases.  Paragraph 5.n. of
      SFAS 13, as amended by SFAS 29, discusses how lease payments that
      depend on an existing index or rate, such as the consumer price index
      or the prime interest rate, should also be included in your minimum
      lease payments.  If, as we assume, they are taken into account in
      computing your minimum lease payments and the minimum lease payments
      are recognized on a straight-line basis over the minimum lease term,
      the note should so state.  If our assumption is incorrect, please tell
      us how your accounting complies with SFAS 13 and FTB 88-1."  We have
      accounted for the lease commitment incorrectly.

      Response:  We have restated the year ending December 31, 2003 and 2004,
      the Balance Sheet as of December 31, 2004, the three months ending
      March 31, 2005 and 2004 and the balance sheet as of March 31, 2005,
      for this error.  Please see footnotes 9 and 12 for further details.

  14. "Your disclosure regarding your basis of presentation indicates that
      Great American Products owns 40% of Promociones GAP, which it accounts
      for under the equity method.  Great American Products' website
      indicates that this joint venture was formed for the exclusive
      production of Great American Products.  Please expand your disclosure
      to explain how you determined these investments would not meet the
      criteria for consolidation under FIN 46(R).  In your discussion, please
      specifically address the analysis you used in concluding that you
      lacked any of the three characteristics of a controlling financial
      interest relating to these investments as discussed in paragraphs 5(a)
      through 5(c) of FIN 46(R).  Please also include in your discussion
      whether or not substantially all of these activities are conducted
      your behalf."

      Response: We have determined we should consolidate Promociones GAP
      because we effectively control Promociones GAP by way of the following:
           a. We are their sole customer
           b. We fund their weekly payroll
      We have determined that FIN46R does not apply to us because we should
      consolidate anyway under traditional accounting rules, which requires
      consolidation because we effectively control Promociones GAP per the
      above.

  15. "You disclosed that your lease for the office and manufacturing
      facility in New Braunfels, TX, expires in 2010.  You further disclosed
      that the building and leasehold improvements are depreciated over 7 to
      40 years.  Please tell us the accounting guidance you used in
      determining it was appropriate to amortize your building and leasehold
      improvements over 7 to 40 years, rather than the shorter of their
      economic lives or the lease term."

      Response:  We direct your attention to the last paragraph of Footnote
      4.  The building is owned by Dyna Group's majority shareholder.  He has
      guaranteed to extend the lease for that period of time or reimburse
      Great American for the unamortized cost of the improvements if the
      lease ever expired before that time.  Therefore leasehold improvements
      were amortized over the shorter of their economic lives or the lease
      term.  Most of the improvements consist of constructing additional
      warehouse space, which is estimated to maintain serviceability for 40
      years.

  16. "The information you have certified to in your Exhibit 31 does not
      include the most current certification requirements.  Please amend
      your Exhibit 31 to include the certifications required by Item 601 of
      Regulation S-B.  See also SEC Release No. 33-8238.  In doing so, please
      file an amended Form 10-KSB/A in its entirety and include updated
      certifications.  Please provide a separate certification for each
      principle executive officer and principal financial officer.  Refer
      to Item 601(b)(31) of Regulation S-B.  Please also ensure that the
      signature page of the Form 10-KSB/A has currently dated signatures.
      Similarly, amend your interim Form 10-QSB in its entirety for the
      period ended March 31, 2005."

      Response:  We amended certifications to include the most current
      certification requirements as well as providing a separate
      certification for each principle executive officer and principal
      financial officer.

  17. "Please address the comments above in your interim Forms 10-Q as
      well."

      Response: The comments for the 10-KSB have been applied to the 10-QSB
      where applicable.

  18. "Please expand your notes to your financial statements to include
      notes for the following:  Debt, income taxes, EPS, other comprehensive
      income, and recent accounting standards."

      Response:  We respectfully disagree with your request for additional
      disclosures related to the items below.  Regulation 210.10-01(a)(5)
      allows registrants to presume that users of interim financial
      information have read or have access to the audited financial
      statements for the preceding fiscal year.  It also allows disclosure
      that would substantially duplicate the disclosure contained in the
      most recent annual report, such as accounting policies and practices,
      details of accounts which have not changed significantly in amount or
      composition since the end of the most recently completed fiscal year
      to be omitted.  Footnote 1 to the March 31, 2005 financial statements
      discloses our reliance on this fact and directs the reader to the
      December 31, 2004 10-KSB.  Responses for each requested disclosure
      are below:

        a. Debt - there were no changes in the terms of this line of credit.
           The terms are disclosed in the December 31, 2004 10-KSB.
           Disclosure at March 31, 2005, would duplicate the December 31,
           2004 disclosure and only provide information that is already
           apparent on the balance sheet as of March 31, 2005, and the
           Statement of Cash Flows for the three months ended March 31, 2005
           and 2004.

        b. Income taxes - the accounting policy and details of the account
           are disclosed in the December 31, 2004 10-KSB.  There were no
           changes to the components of income tax or their accounting for
           the period.  Disclosure at March 31, 2005, would duplicate the
           December 31, 2004 disclosure and only provide information that is
           already apparent on the balance sheet as of March 31, 2005, and
           the Statement of Income and Statement of Cash Flows for the three
           months ended March 31, 2005 and 2004.

        c. EPS - the accounting policy is disclosed in the December 31, 2004
           10-KSB.  There were no changes to how the amount is calculated.
           Disclosure at March 31, 2005, would duplicate the December 31,
           2004 disclosure and only provide information that is already
           apparent on the Statement of Income for the three months ended
           March 31, 2005 and 2004.

        d. Other Comprehensive Income - this amount is deemed immaterial and
           insignificant as of March 31, 2005.

        e. Recent Accounting Standards - the accounting policy and relevant
           information is disclosed in the December 31, 2004 10-KSB.  There
           were no changes to this policy for the first quarter.  Disclosure
           in the March 31, 2005 financial statements would be a duplicate of
           the December 31, 2004 disclosure.

  19. "Please expand your disclosures to include your accounting policy
      regarding marketable securities."

      Response:  An accounting policy for marketable securities has been
      added.  See footnote 1 to the March 31, 2005 financial statements.
      Additional disclosure was added as well.  See footnote 4 to the
      March 31, 2005 financial statements.

  20. "Please expand your disclosure to discuss significant fluctuations in
      your assets and liabilities during the period, including, but not
      limited to the following:  inventory, debt, and accounts payable."

      Response:  We added additional disclosure discussing the fluctuations
      of certain assets, such as obsolete inventory, debt, and accounts
      payable.

  21. "You disclosed that the cost of pewter has risen from $2.70 per pound
      in the first quarter of fiscal 2004 and that the current price per
      pound is $4.40 per pound.  Please expand your disclosure to discuss
      whether you anticipate the trend of increasing costs related to pewter
      to continue and how this may affect your results of operations and
      liquidity."

   Response:  Please see under Results of Operations for changes.

 Regards,

 /s/ Sandra Tristan
 Sandra Tristan, CFO
 Dyna Group International
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