SecProbe.io

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 August 29, 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 your supplemental response what
      the revisions will look like.  With the exception of the comments below
      that specifically request an amendment, all other revisions may be
      included in your future filings.

      Response: We have enclosed on all points, except number 14, the details
      of the changes.

   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: Item 14. Principal Accountant Fees and Services

      For the years ended December 31, 2003 and 2004, the Company's
      independent auditors, Malone & Bailey, P.C. performed the annual
      audit and quarterly reviews of the Company's financial statements
      as well as prepared the annual tax returns.  These related costs
      are listed below:
                                             2003              2004
      Annual audit Fees                 $  37,882.00      $  38,845.00
      Audit related fees-audit reviews      8,975.00         10,740.00
      Tax fees-tax planning, advice         2,300.00          3,890.00

   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: The Company's sales have increased over the past three years
      by $1,953,453, with $1,877,353 of this increase being in 2004.  The
      increase came from two areas, buckle and liscensed sports sales.  The
      reason for the increase in these areas is the rising fashion trend of
      belt buckles and the increased popularity of Major League Baseball,
      with a focus on the Boston Red Sox winning the World Series in 2004.

   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:  Item 1 Business
      The research and development cost for 2003 and 2004 were immaterial.

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

      Response:  The accounting of obsolete inventory, which we determine to
      be material for financial disclosure is as follows:  On all raw
      materials, a one year usage is determined by the previous year's sales,
      and any quantities that are in excess of one year usage on hand are
      identified as obsolete.

   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 obtained license agreements with NASCAR and 18 select
      drivers, the National Football Properties League, Major League
      Baseball, the National Basketball Association, the National Hockey
      League, and Colleges and Universities.  We have recently added Minor
      League Baseball, MTV Networks and Giant Merchandising Collection
      Artists to our list of held licenses.  License agreements are
      periodically renewed, and we do not anticipate significant
      cancellations or non-renewals.  The majority of the license agreements
      have annual renewals.  The remaining license agreements can range from
      two years to automatic rollover renewals.

   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:   Net income was offset by the 26% increase in royalty
      expense.  NFL royalty expense increased by $115,897 as compared to
      2003, and MLB royalty expense increased by $62,114 as compared to 2003.

   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: 8A. Controls and Procedures
      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:  Audit Committee
      At this time, the company does not 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: Item 9.
      Director and Executive officers of the registrant have 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:  REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

 To the Board of Directors
    Dyna Group International, Inc.
    New Braunfels, Texas

 We have audited the accompanying consolidated balance sheets of Dyna Group
 International, Inc., as of December 31, 2004 and 2003 and the related
 statements of consolidated operations, stockholders' equity, and cash flows
 for the years ended December 31, 2004 and 2003.  These financial statements
 are the responsibility of Dyna Group International, Inc.  Our responsibility
 is to express an opinion on these financial statements based on our audits.

 We conducted our audits in accordance with standards of the Public Company
 Accounting Oversight Board (United States).  Those standards require that we
 plan and perform the audits to obtain reasonable assurance about whether the
 financial statements are free of material misstatement.  An audit includes
 examining, on a test basis, evidence supporting the amounts and disclosures
 in the financial statements.  An audit also includes assessing the
 accounting principles used and significant estimates made by management, as
 well as evaluating the overall financial statement presentation.  We believe
 that our audits provide a reasonable basis for our opinion.

 In our opinion, the financial statements referred to above present fairly,
 in all material respects, the financial position of Dyna Group
 International, Inc., as of December 31, 2004 and 2003, and the results of
 its operations and its cash flows for the periods described in conformity
 with accounting principles generally accepted in the United States of
 America.

 As discussed in Note 12 to the financial statements, Dyna Group
 International did not consolidate one of its joint ventures and instead
 accounted for it using the equity method.  Accordingly, adjustments have
 been made as of December 31, 2002, to correct the error.

 MALONE & BAILEY, PC
 www.malone-bailey.com
 Houston, Texas

 February 4, 2005

  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: Licensing fees for the agreements into which Great American
      enters are included under Royalties listed under Revenue and were
      collectively $1,097,705 for 2004 and $869,122 for 2003.

  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."

      Response:  NOTE 9 - COMMITMENTS AND CONTINGENCIES

 Great American leases its facility under  an operating lease agreement  with
 its majority stockholder  which expires  in 2010.   Total  rent expense  was
 $215,000 and $222,084 in 2003 and 2004, respectively.  Total minimum  rental
 commitments as  of December  31,  2004 are  as  follows: $226,403  in  2005,
 $237,723 in 2006, $249,609 in 2007 and $826,235 thereafter.

 NOTE 12 - RESTATEMENTS OF PREVIOUSLY ISSUED FINANCIAL STATEMENTS

 Consolidation

 Lease/rent expense

 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. This restatement reduced 12/31/2002 retained earnings
 by $195,576, increased the rent expense $19720 and 9,452 for period ending
 December 31, 2003 and 2004 respectivefully. 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. We are unable to present this at this time due to the fact that
      we are waiting for additional information from Promociones GAP in order
      to prepare consolidated financial statements

  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:  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 provided certifications for each principal executive
      officer and updated the certifications under Exhibit 31 to the
      following format:

                                Certification
                                -------------
     Pursuant to 18 U.S.C. Section 1350 as Adopted Pursuant to Section 302
     ---------------------------------------------------------------------
                                    of The
                                    ------
                          Sarbanes-Oxley Act of 2002
                          --------------------------

 I, Roger R. Tuttle, certify that:

 1. I  have  reviewed  this  annual  report on  Form  10-KSB  of  Dyna  Group
 International, Inc.;

 2. Based on my knowledge, this report does not contain any untrue  statement
 of a material fact or omit  to state a material  fact necessary to make  the
 statements made, in light of the  circumstances under which such  statements
 were made, not misleading with respect to the period covered by this report;

 3. Based  on my  knowledge, the  financial statements,  and other  financial
 information included in this report, fairly present in all material respects