Dynasil [Logos]
385 Cooper Road
West Berlin, NJ  08091
Phone 856.767.4600
Fax 856.767.6813
info@dynasil.com
www.dynasil.com





                                     August 2, 2010
   BY EDGAR SUBMISSION
   Securities and Exchange Commission
   Washington, DC 20549-4631
   Attention:  Mr. John Hartz
   Attention:  Ms. Mindy Hooker

   Re:        Dynasil Corporation of America
            Form 10-K for the fiscal year ended
            September 30, 2009
            Form 10-Q for the quarter ended
            March 31, 2010
            File No. 0-27503

   Dear Mr. Hartz and Ms. Hooker:

   On behalf of Dynasil Corporation of America
   ("Dynasil" or the "Company"), please find below responses
   to the comments provided to Dynasil by the staff of the
   Commission (the "Staff") in a letter dated July 23, 2010
   (the "Letter") relating to Dynasil's Form 10-K for the
   year ended September 30, 2009 (the "2009 Form 10-K") and
   Dynasil's Form 10-Q for the quarter ended March 31, 2010
   (the "2010 Form 10-Q").  The responses are keyed to the
   numbering of the comments in the Letter and appear
   following the comments which are restated below in
   italics.

  Form 10-Q for the period ended March 31, 2010
  Note 6   Equity, page 10

  We note your response to our prior comment three including
  your statement that "future filings will include the
  reclassification adjustment to move the redeemable common
  stock from permanent equity to temporary equity".  Please
  confirm to us that you intend to correct all prior periods
  presented and that you intend to provide transparent
  disclosures that explain the prior period error you
  determined is immaterial and explain your subsequent
  correction in your next exchange act filing.



  RESPONSE
  As noted in our prior response to comment three, future
  filings will include the reclassification adjustment to move
  the redeemable common stock from permanent equity to
  temporary equity.  All prior periods presented in future
  filings will be corrected. Future filings will include
  transparent disclosures that explain the prior period
  adjustment and subsequent correction that is determined to
  be immaterial.  These disclosures will be included in our
  next exchange act filing which is Form 10-Q for the period
  ended June 30, 2010.

  * * * *
       In response to the Staff's request, the Company
  acknowledges that:

          . the company is responsible for the adequacy and
          accuracy of the disclosure in their filings;
          . 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.

       If you require additional information, please
       telephone the undersigned at 607-272-3320 x33.


                                        Sincerely,



                                        Richard A. Johnson
                                        Chief Financial
                                        Officer
       cc:  Matthew J. Gardella
       Edwards Angell Palmer & Dodge LLP