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DYADIC INTERNATIONAL INC

Regulatory Filings Oct 10, 2014

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RW 1 formrw.htm DYADIC INTERNATIONAL INC RW 10-10-2014 Licensed to: Summit Financial Printing Document created using Disclosure Solutions PROFILE 3.0.0.0 Copyright 1995 - 2014 Thomson Reuters Accelus. All rights reserved.

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[Dyadic International, Inc. Letterhead]

October 10, 2014

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: Dyadic International, Inc. Request for Withdrawal on Form RW

Registration Statement Form 10-12G (File No. 000-55264)

Ladies and Gentleman:

Pursuant to the request of the Staff set forth in Comment No. 1 of the letter from Pamela Long dated September 11, 2014 providing comments on the above Form 10 filing, Dyadic International, Inc. (the “ Company ”) hereby withdraws the filing in order to avoid having the Form 10 become effective prior to completing the comment process with the SEC Staff. The Company desires to work diligently with the Staff to complete the preparation of its Form 10 in a manner responsive to the Staff’s suggestions and comments and to also finalize the Confidential Treatment Request that accompanied Amendment No. 1.

The Company believes that withdrawal of the Registration Statement is consistent with the public interest and the protection of investors. The Company is withdrawing the Registration Statement to prevent it from automatically becoming effective on October 14, 2014, sixty days after its initial filing (pursuant to Exchange Act Section 12(g)(1)). Please note that the Registration Statement was a voluntary filing under Section 12(g) of the Exchange Act.

It is the Company’s understanding that this application for withdrawal of the Registration Statement will be deemed granted as of the date that it is filed with the Commission unless, within fifteen days after such date, the Company receives notice from the Commission that this application will not be granted. Please direct questions with respect to this matter to:

Karen Dempsey

Orrick, Herrington & Sutcliffe LLP

The Orrick Building

405 Howard Street

San Francisco, CA 94105

Telephone: (415) 773-4140

Email: [email protected]

Securities and Exchange Commission Division of Corporation Finance

October 10, 2014

Page 2

Thomas Dubinski, Vice President and Chief Financial Officer

Dyadic International, Inc.

140 Intracoastal Pointe Drive, Suite 404

Jupiter, Florida 33477-5094

Telephone: (561) 743-8333

Email: [email protected]

Very truly yours:
/s/ Thomas L. Dubinski
Thomas L. Dubinski
Vice President and Chief Financial Officer

Cc: Mark Emalfarb

Michael Faby

Karen Dempsey

Andrew Thorpe

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