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April 7, 2005

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street N.W.
Washington, DC  20549-0405

Attention:     Mr. H. Roger Schwall
               Assistant Director
               Division of Corporate Finance

RE:            Gold Standard, Inc.
               Form 10-KSB/A filed February 15, 2005
               File No.  001-08397

Dear Mr. Schwall:

We have reviewed your letter dated March 11, 2005 regarding the above
referenced filing.  We have prepared our response and are prepared to amend
the form 10-KSB/A pending your approval.  Per our discussion with Mr. Jon
Duersch on April 7, 2005, we are submitting this response via Edgar as
correspondence with the Securities and Exchange Commission.

Comment No. 1:

Please revise your filing to include explanatory language, preceding item 1,
identifying the reasons for your amendment, and the corresponding sections
that have changed.

Company's response:

The Form 10-KSB/A filed February 15, 2005 was amended to properly disclose the
pro forma net loss and pro forma loss per share in accordance with Statement
of Financial Accounting Standards No. 123 "Accounting for Stock-Based
Compensation (SFAS No. 123).  This amended disclosure can be found in Note 1
of the Notes to the Consolidated Financial Statements under the caption
"Accounting for Stock-Based Compensation".

Please see our revised Form 10-KSB/A-2 filed on April 7, 2005 which includes
explanatory language, preceding Item 1 that identifies the reasons for the
amendment and the corresponding section that has changed.

Comment No. 2:

Please include page numbers on all future filings, including any amendments
that are necessary.

Company's response:

The revised Form 10-KSB/A-2 filed on April 7, 2005 includes the necessary
information as requested.

Comment No. 3:

We are unable to locate any disclosure in your filing describing the
exploration activities that are associated with your exploration costs.
Please expand your disclosure to explain these activities and to indicate
whether your historical expenditures are indicative of any ongoing exploration
activities.

Company's response:

Exploration activity constitutes gold and other precious metal exploitation
consisting of rock, soil and sediment sampling, geological mapping,
geochemical and geophysical data compilation, auger drilling and government
permits maintenance.

Historical expenditures are not indicative of ongoing exploration activities
as the Company ceased operations in December 2004 in South America where
exploration activities were occurring.

The Company will include this information in future filings.

Comment No. 4:

We note that the Auditor associated with the audit opinion included in your
filing has not been identified.  The report is not in compliance with Rule2-02
of regulation S-X.  Please amend your filing to replace the report with a
signed audit opinion.

Company's response:

The revised Form 10-KSB/A-2 filed on April 7, 2005 includes the information as
requested.

Comment No. 5:

We note that although there have been no significant revenues generated from
your operations you have not characterized your company as an "exploratory
stage" entity.  Therefore, it appears you will need to revise your financial
statement presentation to provide the appropriate cumulative amounts from the
company's inception to comply with paragraph 11 of SFAS 7.  Additionally,
since you are in an extractive industry, it will be necessary to revise the
disclosures and labeling throughout your document to characterize the company
as an "exploratory stage" entity, rather than a "development stage" entity as
that term has specific meaning within the extractive industry which describes
an advanced mining activity in which proved reserves have been determined.

Company's response:

The Company's planned principal operations have consisted of reviewing
geological sites from maps for potential ore deposits and drilling small core
samples to determine if a specific site is suited for continued exploration
activity and potential extraction of precious metals.  Once a site has been
determined to have potential for significant ore deposits, the Company sells
the rights to extract the precious metal or joint ventures with an extraction
company that is better suited to perform the mining function.  As a result,
the Company earned royalty revenues of $485,624 and $339,726 in 1995 and 1996,
respectively.

In addition, exploratory stages for the extraction industry would include
activities such as establishing sources of supply, acquiring property and
equipment, recruiting and training personnel, developing markets and starting
up production as well as raising capital to fund operations.  These activities
were accomplished years ago as evidenced by the Company's long reporting
history and accumulated deficits from continued operations, which suggest that
planned principal operations had long since begun.

Currently, the Registrant has no royalty revenues and has ceased operations.
The financial statements and notes to the financial statements as filed on
February 15, 2005 disclose the amount of accumulated deficit, the financial
condition of the Company, the status of operations, the status of exploration
activities and a going concern opinion from the Registrant's independent
auditors.  Further, the Registrant's stock has not had significant trading
activity.  Given these matters and the financial condition of the Registrant,
we believe that the current disclosures are adequate and we do not believe
that the suggested disclosure would provide additional, meaningful information
to the investors.

We appreciate your comments and suggestions which will assist us in our future
filings.  If members of the Staff have any further comments or questions or
require any additional information, please contact me by telephone at 801-328-
4452 or by facsimile at 801-328-4457.

Very truly yours,

/s/Scott L. Smith

Scott L. Smith
President and Chief Executive Officer

<PAGE>

             U. S. Securities and Exchange Commission
                     Washington, D. C. 20549

                           FORM 10-KSB/A-2

[X]  ANNUAL REPORT UNDER SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT
     OF 1934

     For the fiscal year ended October 31, 2004

[ ]  TRANSITION REPORT UNDER SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE
     ACT OF 1934

     For the transition period from _________________ to __________________

                     Commission File No.  001-08397

                          GOLD STANDARD, INC.
                          -------------------
          (Name of Small Business Issuer in its Charter)

             UTAH                                      87-0302579
             ----                                      ----------
  (State or Other Jurisdiction of              (I.R.S. Employer I.D. No.)
 incorporation or organization)

                      136 South Main Street, Suite 712
                        Salt Lake City, Utah 84101
                        --------------------------
                  (Address of Principal Executive Offices)

            Issuer's Telephone Number: (801) 328-4452

Securities registered under Section 12(b) of the Act: None

Securities registered under Section 12(g) of the Act:

                     Common Stock, $0.001 par value
                     ------------------------------

         Check whether the Registrant (1) filed all reports required to be
filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 (the
"Exchange Act") during the past 12 months (or for such shorter period that the
Registrant was required to file such reports), and (2) has been subject to
such filing requirements for the past 90 days.

     (1)   Yes  X    No            (2)   Yes  X    No
               ---     ---                   ---     ---

         Check if there is no disclosure of delinquent filers in response to
Item 405 of Regulation S-B contained in this form, and no disclosure will
be contained, to the best of the Registrant's knowledge, in definitive proxy
or information statements incorporated by reference in Part III of this Form
10-KSB or any amendment to this Form 10-KSB.  [ ]

         The Registrant had $0 in revenues for the fiscal year ended October
31, 2004.

         As of January 31, 2005, 8,079,552 shares of the Registrant's common
stock held by non-affiliates and the market value of the Registrant's common
stock (based on the closing price of the shares on the OTB Bulletin Board),
was approximately $1,131,137.

         The Registrant has not been involved in any bankruptcy proceedings.

         The number of shares of the Registrant's common equity outstanding as
of January 31, 2005, was 10,458,864 shares of common stock.

         A description of "Documents Incorporated by Reference" is
contained in the Exhibit Index, Part III, Item 13, of this Annual Report.

         Transitional Small Business Disclosure Format: Yes X   No
                                                           ---    ---

On February 15, 2005, the Registrant filed a Form 10KSB/A-1.  Based upon a
review performed by the Securities and Exchange Commission on the Form
10KSB/A-1, the Registrant hereby amends such Form 10KSB/A-1 to include page
numbers in the filing, to include the auditor's name associated with the audit
opinion which was excluded when converted to the EDGAR format in the previous
file and to provide an explanation of the reason for amending the above
mentioned filing.  The previous filing was amended to properly disclose the
pro forma net loss and pro forma loss per share in accordance with the
Statement of Financial Accounting Standards No. 123 "Accounting for Stock-
Based Compensation".

<PAGE>                          1

                                     PART I

Item 1.  Description of Business.

Business Development.
---------------------
     General.
     --------

          Gold Standard, Inc. was incorporated pursuant to the laws of the
State of Utah on November 28, 1972, for the purpose of engaging in the
exploration, production and sale of gold.  The Company and its subsidiaries
(the "Company") seek to acquire, lease and sell hard mineral properties and,
if warranted, develop those properties which have the most economic potential.
The Company also seeks opportunities for joint ventures or other financial
arrangements with other companies to develop and/or operate the properties
controlled by the Company or in which it has an interest.   Currently the
Company has no development or other operations. There is no assurance that a
commercially viable ore body (reserves) exists in any of the Company's
properties.

     Material Developments During Fiscal 2003.
     -----------------------------------------

          Effective May 2, 2003, the Company effected forward split of its
outstanding securities by an eight for one dividend, while retaining the
authorized shares and par value, and with appropriate adjustments in its
capital accounts.  All computations contained in this Annual Report take this
recapitalization into account.

     Material Developments During Fiscal 2004.
     -----------------------------------------

          On December 22, 2003, the Company sold 1,100,000 shares of its
common stock that are "restricted securities" as that term is defined under
Rule 144 of the Securities and Exchange Commission in consideration of the sum
of $250,000.  The Company anticipated utilizing these funds to conduct further
exploration activities, following its preliminary exploration activities, on
its Brazilian prospects that are under control of the Company by a grant of
mineral rights from the Brazilian government.

     Material Events Subsequent to Fiscal 2004.
     ------------------------------------------

          Subsequent to the fiscal year end of October 31, 2004, the Company
suspended operations on its mining properties in Brazil, due to lack of
funding available to continue exploratory operations.  The office has been
closed and the physical assets that comprised that facility have been sold.
The Company is seeking joint venture partners with which it can recommence
such operations.

Business.
---------

          Since the 1994-1995 period, the Company has acquired certain mineral
rights in the country of Brazil.  Until recently, when these operations were
suspended, exploration activities in Brazil were carried on through the
Company's wholly-owned Brazilian subsidiary, Gold Standard Minas, S.A.
<PAGE>                          2
         To conduct its exploration activities in Brazil, Gold Standard Minas
maintained offices in Curitiba, Parana, Brazil.  Gold Standard Minas had 12
employees consisting of senior and junior geologists, technicians, prospectors
and laborers.  All employees of Gold Standard Minas were Brazilian nationals.
If exploration activities are resumed, this may or may not be the case.

         The Company has two other subsidiaries, both of which are
non-operating.  Gold Standard South was organized for the purpose of carrying
on a property acquisition and gold exploration program in the country of
Uruguay.  Tormin, S.A., at one time, held certain mineral exploration
concessions in Uruguay; the operations ceased for these two subsidiaries in
prior years.

         For the past year, the Company has been exploring opportunities to
merge or combine with another operating business in an attempt to diversify
the Company's operations and capitalize on the Company's status as a publicly
held company.  The Company currently intends to continue its efforts in this
regard.

         The Company's offices are located at 136 South Main Street, Suite
712, in Salt Lake City, Utah 84101 where it rents office space on a month to
month basis. In addition to the President, Scott L. Smith, the Company has two
part-time employees located in Salt Lake City, Utah, serving the Company at
this location.

Effect of Existing or Probable Governmental Regulations on Business.
--------------------------------------------------------------------

     Brazilian Mining Law.
     ---------------------

          The mining law of Brazil is clear cut and quite standard to
international procedures.  All minerals belong to the state.  Companies both
foreign and domestic as well as individuals can exploit these minerals by
applying for claims to the Brazilian Mining Agency (the "DNPM").  Upon
applying for a claim to prospect, DNPM notifies the applicant whether the
prospect is open and whether priority is granted or will not be granted.  Upon
receiving priority status, the next step is the granting of the alvara, which
is the permanent mineral claim.  The actual mining permit is granted by the
DNPM after satisfying the necessary environmental standards and showing the
DNPM the requisite intention of going into production.  The DNPM maintains an
Internet web site at DNPM@gov.br.  The Company believes that unless it finds
an economically viable ore body, that the requirements of Brazilian mining law
to which its present exploration activities are subject, are not material to
these operations; and if an economically viable ore body is discovered through
the Company's current exploration activities, the Company believes that it
will be able to satisfy all requisite requirements of Brazil to proceed with
development operations respecting any such ore body, including environmental
regulations.

     Small Business Issuer.
     ----------------------

          The integrated disclosure system for small business issuers
adopted by the Securities and Exchange Commission in Release No. 34-30968 and
effective as of August 13, 1992, substantially modified the information and
financial requirements of a "Small Business Issuer," defined to be an issuer
that has revenues of less than $25 million; is a