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DynaResource, Inc.

222
W. Las Colinas Blvd

Suite
1910 North Tower

Irving,
Texas 75039

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, 2017

    Filed April 16, 2018

    File No. 000-30371

Ladies
and Gentlemen:

We
received your letter dated December 18, 2018 seeking additional detail concerning our December 18, 2018 response to your
initial November 28, 2018 comments to the referenced Annual Report on Form 10-K for DynaResource, Inc. (the
“Company”), File 000-30371. We have restated the Commission’s comment below and have included our response
to the comment:

In
response to the following enumerated comments in the Comment Letter, we respectfully submit the following responses:

Form
10-K for Fiscal Year Ended December 31, 2017

Notes
to Consolidated Financial Statements

Note
1. Nature of Activities and Significant Accounting Policies

Property

Design,
Construction and Development Costs, page 57

 1. We
                                         have reviewed your response to comment 1 noting you do not believe the costs you capitalized
                                         for the medical facility, camp, office infrastructure improvements, tailings pond and
                                         liner improvements, new foundation for the Denver Mill, installation cost for Mill #3,
                                         other machinery and equipment and transportation equipment related to mine development.
                                         Considering you have not established proven and probable reserves for this mine and you
                                         continue to be in the exploration stage, please provide us with a detailed discussion
                                         of how you determined the probable future economic benefit for each of these capitalized
                                         costs, including: (a) your expected proceeds and associated costs from alternative future
                                         uses for each of these capitalize costs and (b) the salvage value for each of these capitalized
                                         amounts. Also tell us the basis for each of your material assumptions, including providing
                                         supporting evidence.

Response:

Because
the fiscal 2017 DynaResource mining operations has only one source of revenue, the sale of minerals (primarily gold and
silver), extracted and processed from the mining and milling operations, it is impractical to perform a separate detailed
analysis of the probable future economic benefit for each of the capitalized costs.

While
we had not established “proven and probable reserves” under SEC Guide 7 (please note however the Company does
report 402,000 “Indicated” Oz Au and 741,000 “Inferred” Oz Au under the definitions described in
Canadian National Instrument 43-101), the Company has established a proven revenue stream from its mining and milling
operations. Total revenues for the year ended December 31, 2018 were approximately $14,000,000, an increase of approximately
30% over total revenues received for the year ended December 31, 2017. Forecasted revenue for the year ending December 31,
2019 is $30,000,000. Our analysis of the future economic benefit of the capitalized costs is based on our 2017 and 2018
revenue and the additional revenue we expect to generate through the expansion of our processing facilities in 2019 and
thereafter. All the capitalized costs in 2017 discussed in your comments as well as additional costs incurred in 2018 are
necessary to support and process the increased mining and milling operations.

None
of the capitalizable items have significant expected proceeds from alternative uses or if salvaged. Therefore, neither were factors
considered in our determination of the future economic benefit of the assets.

The
Company’s mining and milling operations are  in the Construction phase, and these assets qualify as construction assets
as defined by Guide 7. Construction assets and facilities are infrastructure, building, machinery, plant and equipment
necessary to extract, treat, and transport material from the mineral reserve. Per Guide 7, construction assets have a separate
measurable life which may be longer or shorter than the mine.

The
Company is currently in the process of evaluating what updates and additional disclosures  may be required to include in
the Company’s Form 10-K for the year ended December 31, 2018 relating to its progression of defining proven or probable
reserves on its properties (in addition, the Company will plan to file the NI 43-101 Technical Report referred to above under
the revised definitions approved recently by the SEC as an update to SEC Guide 7), as well as whether the Company’s mining
and milling operations are currently in the Construction or Production phase as previously defined by Guide 7.

***

The
Company acknowledges that the Company and its management are responsible for the adequacy and accuracy of the disclosure in the
filing, notwithstanding any review, comments, action or absence of action by the staff of the Commission.

Respectfully,

/s/
K.W. (“K.D.) Diepholz

Chairman
/ CEO