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DynaResource, Inc.

222 W. Las Colinas Blvd.

Suite 744 East Tower

Irving, Texas 75039

(972) 868-9066

February 1, 2013

Mr. John Reynolds

Assistant Director

Division of Corporate Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

    RE:
    DynaResource, Inc.

    Form 10-K for Fiscal Year Ended December 31, 2011

    Filed April 2, 2012

    File No. 000-30371

Dear Mr. Reynolds:

We received your letter dated December 18,
2012 with comments to the referenced Annual Report on Form 10-K for DynaResource, Inc. (the “Company”), File No. 000-30371.
We have restated the Commission’s comments below -- including open comments from the staff’s October 31 and November
21, 2012 letters -- and have included our responses to each comment.

General

1. 	[from
October 31 letter] We note that you disclose mineral resources throughout your filing. As a company
incorporated in Delaware, the provisions in Industry Guide 7 preclude the use of any terms other than proven or probable reserves
for disclosure in filings with the United States Securities and Exchange Commission, pursuant to paragraph (b)(5)(3) of Industry
Guide 7. Please substantially revise your filing and remove all mineral resource disclosure.

1.	[from November 21 letter] We note your
response to comments 1, 2, and 5 from our letter dated October 31, 2012. As a company incorporated in Delaware, only proven and
probable reserves may be disclosed in filings with the United States Securities and Exchange Commission. The exemption to which
you refer is only applicable if you are incorporated in a foreign jurisdiction. We reissue the comments.

1.	 [from December 18 letter] We note your
response to comment 1 from our letter dated November 21, 2012. Choosing to list a security on a foreign exchange does not pre-empt
you from complying with U.S. securities regulation. Therefore, the exemption regarding mineral estimates in Instruction 3 to section
(b)(5) of Industry Guide 7 is for companies whose jurisdiction is outside of the United States. This guidance is not new and is
applicable to many companies. We reissue the comment.

Response:

The Company will update its disclosure via
an amendment to the Form 10-K, to remove all mineral resource disclosure.

2. 	[from October 31 letter] We note that
you have included a general disclaimer regarding Canadian mineral resource and mineral reserve reporting standards on page 4 of
your disclosure. This appears to be a disclaimer that Canadian incorporated companies include in their United States filings and
is not applicable to companies incorporated in the United States. Please advise.

Response: Page 4 of the Company’s
Form 10-K contains a section to describe the Canadian securities disclosure regime. As a point of information, the disclosure regime
is not limited to Canadian public companies, but extends to foreign (that is, non-Canadian) public companies, including those which
have become subject to Canadian law. The Company has become an “OTC reporting issuer” in Canada, and consequently is
subject to the Canadian securities disclosure regime.

In view of the response to comment #1, the
section describing the Canadian securities disclosure regime has been revised in its entirety, to read as follows:

CAUTIONARY
NOTE TO UNITED STATES INVESTORS—INFORMATION CONCERNING

PREPARATION OF RESOURCE AND RESERVE ESTIMATES

The
Company is required to prepare reports under the Canadian Securities Administrators’ National Instrument 43-101 “Standards
of Disclosure for Mineral Projects” (“NI 43-101”), under the Canadian securities laws because we are subject
to Canadian securities laws. These standards are materially different from the standards generally permitted in reports filed with
the United States Securities and Exchange Commission (“SEC”).

The
terms “mineral reserve”, “proven mineral reserve” and “probable mineral reserve” used in this
report are Canadian mining terms defined in accordance with the Canadian Institute of Mining, Metallurgy and Petroleum (the “CIM”)
in the CIM Standards on Mineral Resources and Mineral Reserves, adopted by the CIM Council. These definitions differ from the definitions
of those terms in Industry Guide 7 (“Guide 7”) promulgated by the SEC. Under U.S. standards, mineralization may not
be classified as a “reserve” unless a determination has been made that the mineralization could be economically and
legally produced or extracted at the time the reserve determination is made. Under Guide 7 standards, a “Final” or
“Bankable” feasibility study is required to report reserves, the three-year historical average precious metals prices
are used in any reserve or cash flow analysis to designate reserves, and the primary environmental analysis or report must be filed
with the appropriate government authority. One consequence of these differences is that “reserves” calculated in accordance
with Canadian standards may not be “reserves” under Guide 7 standards. U.S. investors should be aware that the Company’s
properties located in Mexico do not have “reserves” as defined by Guide 7 and are cautioned not to assume that any
part or all of the disclosed mineralized material will be confirmed or converted into Guide 7 compliant “reserves”.

Under NI 43-101, we report measured, indicated
and inferred resources, which are measurements that are generally not permitted in filings made with the SEC. The estimation of
measured resources and indicated resources involve greater uncertainty as to their existence and economic feasibility than the
estimation of proven and probable reserves. U.S. investors are cautioned not to assume that any part of measured or indicated resources
will ever be converted into economically mineable reserves. The estimation of inferred resources involves far greater uncertainty
as to their existence and economic viability than the estimation of other categories of resources. It cannot be assumed that all
or any part of inferred resources will ever be upgraded to a higher category. Therefore, U.S. investors are also cautioned not
to assume that all or any part of inferred resources exist, or that they can be mined legally or economically.

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Item 2 Properties page 15

5. 	[from October 31 letter] For each of
your properties please provide a clear statement that the property is without known reserves and the proposed program is exploratory
in nature, pursuant to paragraph (b)(4)(i) of Industry Guide 7.

Response: The Company will update its
disclosure via an amendment to the Form 10-K, to provide a clear statement that the property is without known reserves and that
currently, the Company’s drilling program is exploratory in nature. The Company proposes the following text:

No Known Reserves

Currently, the Company’s drilling programs
are exploratory in nature.

The SJG property is without known reserves.
Under U.S. standards, mineralization may not be classified as a “reserve” unless a determination
has been made that the mineralization could be economically and legally produced or extracted at the time the reserve determination
is made.

***

The Company acknowledges that:

 · the Company is responsible for the adequacy and accuracy of the disclosure
in the filing;

 · staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to the filing; and

 · the Company may
not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

Please let me know if you have further questions,
or if you need any further clarification on the responses provided. Thank you for your professional attention.

Respectfully,

/s/ K.W. (“K.D.”) Diepholz

K.W. (“K.D.”) Diepholz

Chairman / CEO

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