SecProbe.io

January 30, 2015

Via E -mail
Mr. William O’Dowd IV
Chief Executive Of ficer
Dolphin Digital Media, Inc.
2151 LeJeune Road, Suite 150
Coral Gables, FL 33134

Re: Dolphin Digital Media, Inc.
Form 10 -K for Fis cal Year Ended December 31, 2013
Filed August 15, 2014
Form 10 -Q for Fiscal Quarter Ended June 30, 2014
Filed August 21, 2014
Response Dated January 20, 2015
File No. 000 -50621

Dear Mr. O’Dowd :

 We have reviewed your response letter a nd 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 this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response  to these comments, we may
have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2013

Item 1. Business, page 1

1. We note your response to Comment 2. Please update this section. Clearly distinguish and
balance historical, current and aspir ational operation, and do not place an undue emphasis
on cancelled agreements or defunct projects.

Dolphin Digital Studios, page 2

2. We note your response to Comment 3. Please provide greater detail as to where your
eleven projects currently stand in the v ideo production cycle.

Mr. William O’Dowd IV
Dolphin Digital Media, Inc.
January 30, 2015
Page 2

Cambio Distribution Partnership, page 4

3. We note your response to Comment 6. We further note that Cambio is currently listed as
a partner of Dolphin Digital Studios on your website. Please advise. We additionally note
that Facebook is listed as a partner of Dolphin Digital Studios on your website . Please
provide greater detail, or advise, as to any business or distribution relationship with
Facebook.

Kids Clubs, page 4

4. We note your response to Comment 7. Please provide greater detail as to how your
partnership with Club Connect relates to and i s integrated into your video production
business.

Item. 1A. Risk Factors, page 6

Certain Risk Factors Relating to our Business, page 7

5. We note your response to Comment 8. Please revise your risk factors so that they are
narrowly tailored towards your p articular business plan and highlight the current status of
your business operations.

Item 7. Management’s Discussion and Analysis, page 12

6. We note your response to Comment 11 as well as the information provided in Annexes A
and B. Please provide greater  detail as to the Company’s current video content
distribution operations and related revenue generation.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the info rmation the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the di sclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging 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

Mr. William O’Dowd IV
Dolphin Digital Media, Inc.
January 30, 2015
Page 3

  the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the fe deral securities laws of the United States.

You may contact Michael Henderson, Staff Accountant, at (202) 551 -3364  or Terry
French, Accountant Branch Chief, at (202) 551 -3828 if you have questions regarding comments
on the financial statements and related  matters.  Please contact William Mastrianna,  Attorney -
Advisor, at (202) 551 -3778 , Celeste M. Murphy, Legal Branch Chief, at (202) 551 -3257 , or me
at (202) 551 -3810 with any other questions.

Sincerely,

/s/ Celeste M. Murphy for

Larry Spirgel
Assistant Director

cc: Via E -mail
 Kara L. MacCullough, Esq.
 Greenberg Traurig, P.A.