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DynaResource, Inc.

222 W. Las Colinas Blvd.

Suite 744 East Tower

Irving, Texas 75039

(972) 868-9066

Ms. Tia L. Jenkins	November 23, 2015

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, NE

Washington, DC 20549

RE:	     DynaResource, Inc.

Form 10-K for Fiscal Year Ended December
31, 2014

Filed May 6, 2015

File No. 000-30371

Dear Ms. Jenkins:

We received your letter dated October
21, 2015 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 and have included our responses to each comment.

Properties, Page 16

Property Location, Page 17

 1. Please modify your filing and insert a small-scale map showing the
location and access to each material property, as required by Instruction 3(b) to Item 102 of Regulation S-K. Please note the EDGAR
program now accepts maps in certain electronic formats, so please include these maps in your amendments upload to EDGAR. For more
information, please consult the EDGAR manual, and if additional assistance is required, please call Filer support at (202) 551-8900
for Post-Acceptance Filing Issues or (202) 551-3600 for Pre-Acceptance Filing Issues. We believe the guidance in Instruction 3(b)
of Rule 102 of Regulation S-K would generally require maps and drawings to comply with the following features:

 · A legend or explanation showing, by means of pattern or symbol, every
pattern or symbol used on the map or drawing.

 · A graphical bar scale should be included. Additional representations
of scale such as “one inch equals one mile” may be utilized provided the original scale of the map has not been altered.

 · A north arrow.

 · An index map showing where the property is situated in relationship
to the state or province, etc., in which it was located.

 · A title of the map or drawing, and the date on which it was drawn.

 · In the event interpretive data is submitted in conjunction with any
map, the identity of the geologist or engineer that prepared such data.

Any drawing should be simple enough
or of sufficiently large scale to clearly show all features on the drawing.

    pg. 1

Response:

We will amend our filing in order
to insert small-scale maps showing the location and access to each material property. Each map will reflect the features suggested.

San Jose de Garcia – History,
Page 21

 2. We note you disclose previous mining activities on your properties.
Please amend your filing and elaborate on any surface disturbance or contamination issues found on the surface or in the groundwater
due to historical mining activities. The extent and significance of the disturbance/contamination, as well as your plans to remediate
the site, should be clear.

Response:

We will amend our filing in order to
address the existence (or absence) of any surface disturbance or contamination issues found on the surface or in the groundwater
due to historical activities.

Our filing will include disclosure substantially
as follows:

Historical production at San Jose de
Gracia occurred prior to the Mexican Revolution (pre 1910). The Company is not aware of any surface disturbance or contamination
issues found on the surface or in the groundwater due to historical mining activities.

Since acquisition and consolidation of
the project under DynaResource de Mexico SA de CV. (“DynaMéxico”), all activities conducted at San Jose
de Gracia have been permitted in accordance with Mexico regulations, the specifics of which are described below:

On June 17, 2013, DynaResource de Mexico
received from the Secretaria de Medio Ambiente Y Recursos Naturales (“Semarnat”), the federal environmental authority
in Mexico, the approval and permission which allows for the rehabilitation and operation of the pilot mill facility at San Jose
de Gracia (the “Semarnat Permit”). Under the terms of the Semarnat Permit, DynaMexico is responsible for maintaining
the San Jose de Gracia pilot mill facility, as well as the adjacent tailings pond area, in compliance with Semarnat regulations.

On September 30, 2013 DynaResource de
Mexico also received from Semarnat, the approval and permission which allows for the exploitation and mining activities at the
San Pablo Area of San Jose de Gracia (the “Semarnat Exploitation Permit”). Under the terms of the Semarnat Exploitation
Permit, DynaMéxico’s exploitation and mining activities are restricted to the San Pablo Area of San Jose de Gracia.

As a point of information, the area
covered by the Semarnat Exploitation Permit does not require any environmental impact study, as there are no new surface disturbances
contemplated in the current operations.

Mineral Resources Estimate for
the San Jose de Garcia Property (2012), page 23

 3. We note you have disclosed resources estimates for your property
that conform to Canada’s National Instrument 43-101. The provisions in Industry Guide 7 preclude the use of any terms other
than proven or probable reserves for disclosure in SEC documents. Please amend your filing to remove all resource quantity and
quality disclosure from your filing.

Response:

We will amend our filing to remove all
resource quantity and quality disclosure from our filing, including any mention of those portions of the NI 43-101 Technical Report
which refer to resource quantity and quality in either prose or graph format.

    pg. 2

 4. At various locations elsewhere in your filing, you use the terms
measured, indicated, and/or inferred resources to quantity estimates. The provisions in Industry Guide 7 preclude the use of any
terms other than proven or probable reserves for disclosure in SEC documents. Please amend your filing to remove all resource disclosure
from your filing.

Response:

We will amend our filing in order
to remove all resource quantity and quality disclosure, including any mention of those portions of the NI 43-101 Technical Report
which refer to resource quantity and quality (such as “measured,” “indicated,” or “inferred”
resources) in either prose or graph format.

Test Underground Mining and Pilot
Mill Operations, Page 29

 5. Please disclose your annual production as required by Item 102 of
Regulation S-K Instruction 3. This would include your metallurgical recovery, the tonnes and grade of your material mined, material
processed, and concentrate/dore produced. In addition, please disclose the ounces of gold produced and ounces of gold sold.

Response:

We will amend our filing in order to
disclose our annual production as required by Item 102 of Regulation S-K Instruction 3.

For clarity, our filing will include
additional information substantially as follows:

        Period

        Total Tons

        Mined & Processed

        (Gravity Only)

        Reported Mill Grade

        (g/t Au)

        Reported Recovery

        Gold Production

        (Au oz.)

        Net Gold Sold

        (Au oz.)

    2014
    5,156
    12.45
    ~45%
    929
    830

        Period

        Total Tons

        Mined and Processed

        (Gravity + Flotation)

        Reported Mill Grade

        (g/t Au)

        Reported Recovery

        Gold Production

        (Au oz.)

        Gold Sold

        (Au oz.)

    2014

        3,694

    7.86
    ~80%
    747
    608

 6. Please modify your filing and disclose the information required under
paragraph (b) of Industry Guide 7 for all your material properties listed under this heading. For any properties identified that
are not material, please include a statement to that effect, clarifying your intentions. For each material property, include the
following information:

 · A description of any work completed on your property and its present
condition.

 · The details as to modernization and physical condition of your processing
plant and equipment.

 · Describe your mine, including surface or subsurface improvements
and mining equipment.

 · Provide a description of your equipment, infrastructure, and other
facilities.

 · If applicable, provide a clear statement that the property is without
known reserves and the proposed program is exploratory in nature.

    pg. 3

  You may refer to Industry Guide 7, paragraphs (b) (1) through (5), for specific guidance pertaining
to the forgoing, available on your website at the following address:

www.sec.gov/about/forms/industryguides.pdf

Response:

We will amend our filing in order
to disclose the information required under paragraph (b) of Industry Guide 7, entitled “Mining
Operation Disclosure,” for all of our material properties.

Management’s Discussion and
Analysis of Results of Operations and Financial Condition, Page 33

Results for the Years Ended December
31, 2014 and 2013 page 35

 7. We note your statement that you are still in the
development stage in this section. The terms development and production have a specific meanings within Industry Guide 7 (see www.sec.gov/about/forms/industryguides.pdf).
These words/terms reference the development stage when companies are engaged in preparing reserves for production, and the production
stage when companies are engaged in commercial-scale, profit oriented extraction of minerals. Since you do not disclose any reserves
as defined by Guide 7, please remove the terms develop, development or production throughout your document, and replace this terminology,
as needed, with the terms such as explore or exploration.

Response:

We will amend our filing in order to
remove any statement that the Company is or has been in the development stage.

For clarity, our filing will include
information referencing production, solely as it relates to the Company’s test mining and pilot mill operations at San Jose
de Gracia, and distinguish those operations from commercial-scale production.

Financial Statements and Supplementary
Data, page 41

Notes to the Consolidated Financial
Statements, page 47

Note 1- Nature of Activities and
Significant Accounting Policies

Per Share Amounts, page 51

 8. Please revise to quantify the securities that could potentially dilute basic EPS in the future
that were not included in the computation of diluted EPS because to do so would have been anti-dilutive for the periods presented.
Refer to ASC 260-10-50-1(c).

Response:

We will amend our filing so that the
section entitled “Per Share Amounts,” in the second paragraph thereof, will read substantially as follows: At December
31, 2014, the Company had 1,259,650 warrants outstanding which, upon exercise, would result in the issuance of 1,259,650 shares
of common stock. Also at December 31, 2014, the Company had convertible debt instruments outstanding which, upon conversion, would
result in the issuance of 373,829 shares of common stock. In addition, upon such conversion, the holders of the convertible debt
instruments would receive warrants exercisable for an aggregate of 373,829 shares of common stock. As the Company incurred a net
loss during the period ended December 31, 2014, the basic and diluted loss per common share is the same amount, as any common stock
equivalents would be considered anti-dilutive and, therefore, have been excluded from the computation.

    pg. 4

As a point of information, at fiscal
year-end 2013, the Company had 12,789,978 shares outstanding on a fully-diluted basis, and at fiscal year-end 2014, the Company
had 16,153,332 shares outstanding on a fully-diluted basis.

Controls
and Procedures, page 65

 9. We note that you concluded both your disclosure controls and procedures
(“DC&P”) and internal control over financial reporting (“ICFR”) were effective as of December 31, 2014.
We further note the revisions to prior period financial statements disclosed in Note 13 that appear to have resulted from multiple
errors that were identified. Please explain to us the basis for conclusions on the effectiveness of both your DC&P and ICFR
as of December 31, 2014. Also tell us how and when these prior financial statements errors were identified.

Response:

On March 9, 2015, the Company retained
the public audit accounting firm of MaloneBailey, LLP, located in Houston, Texas (“MaloneBailey”). MaloneBailey audited
the consolidated financial statements of the Company for the fiscal years ending December 31, 2013 and 2014. During the course
of its audit, MaloneBailey identified items and suggested the adjustments described in Note 13 to the financial statements, and
the Company revised its financial statements for prior periods, to reflect such adjustments.

The Company evaluated the effect of the
financial statement revisions on all relevant periods in accordance with Staff Accounting Bulletin (“SAB”) 99 and SAB
108, and determined that the impact of the revisions on its previously filed annual financial statements for the fiscal years ended
December 31, 2011, December 31, 2012, and December 31, 2013, was not material.

The revisions that were made to prior
periods as described in Note 13, when taken as a whole, did not result in a material effect on the financial statements of the
Company.

Accordingly, our original conclusion
on the effectiveness of the Company’s disclosure controls and procedures and internal control over financial reporting as
of December 31, 2014 is unchanged.

Management’s Annual Report
on Internal Control Over Financial Reporting, page 65

 10. On May 14, 2013, Committee of Sponsoring Organizations (“COSO”)
issued its updated Internal Control - Integrated Framework (the “Updated Framework”). We note your Management’s
Annual Report on Internal Control Over Financial Reporting does not identify the version of the Internal Control – Integrated
Framework that was used to perform your assessment as required by item 308(a)(2) of Regulation S-K. Please tell us the framework
you used - i.e., whether you used the 1992 Framework or the Updated Framework issued in 2013, and confirm that you will revise
future filings to include a report that identifies the version of the COSO Integrated Framework you used in the assessment of your
internal control over financial reporting.

Response:

The Internal Control – Integrated
Framework we used was the original framework from 1992 required by Section 404 of the Sarbanes Oxley Act of 2002.

We are developing our plan to transition
from the original framework to the COSO 2013 Internal Control - Integrated Framework.

We will include in future filings a
report that identifies the version of the COSO Integrated Framework used in the assessment of internal control over financial reporting.

    pg. 5

Changes in Internal Controls over
Financial Reporting, page 65

 11. We note your disclosure that you have not made any changes in your
internal controls over financial reporting that occurred during the period covered by this report on Form 10-K. Please tell us
whether the Company has made any changes, or plans to make future changes, to address the significant deficiencies and/or material
weaknesses that resulted in the errors identified in prior financial statements disclosed in Note 13.

Response:

As noted in our response to comment number
9, our original conclusion on the effectiveness of the Company’s disclosure controls and procedures and internal control
over financial reporting as of December 31, 2014 was unchanged.

However, in view of our auditor’s
identification of the few items requiring adjustment identified in Note 13, and the Company’s revision of its financial statements
for prior periods to reflect such adjustments, the Company is continually looking for ways to enhance its internal controls over
financial reporting.

Further
to these responses to your comments as provided above, we respectfully request your permission to include the changes you
have requested in the Form 10-K for fiscal year ending December 31, 2015 in lieu of amending the Form 10-K for fiscal year ending
December 31,