SecProbe.io

May 22, 2019
K.W. Diepholz
Chairman and Chief Executive Officer
DynaResource, Inc.
222 W. Las Colinas Blvd.
Suite 1900 North Tower
Irving, Texas 75039
Re:DynaResource, Inc.
Form 10-K for Fiscal Year Ended December 31, 2018
Response Dated April 24, 2019
File No. 000-30371
Dear Mr. Diepholz:
            We have reviewed your April 24, 2019 response to our comment letter 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional
comments.  Unless we note otherwise, our references to prior comments are our February 25,
2019 oral comments.
Form 10-K for Fiscal Year Ended December 31, 2018
Notes to the Consolidated Financial Statements
Note 1. Nature of Activities and Significant Accounting Policies
Proven and Probable Reserves (No Known Reserves), page 57
1.We note you reference a mine plan throughout the document including page 29 in which
you reference a formal mine plan.  Please confirm whether or not you have a formal mine
plan, including the period of time the plan covers.
2.If you do not have a current mine plan, please tell us, in detail, i) how you conduct your
mining operations, ii) how you determine where to mine and iii) how you make capital
investment decisions.

 FirstName LastNameK.W. Diepholz
 Comapany NameDynaResource, Inc.
 May 22, 2019 Page 2
 FirstName LastName
K.W. Diepholz
DynaResource, Inc.
May 22, 2019
Page 2

            You may contact Blaise Rhodes at 202-551-3774 or Angela Lumley at 202-551-3398
with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining