SecProbe.io

January 9, 2013

Via E -mail
Mr. Mitchell J.  Krebs
President and Chief Executive Officer
Coeur d’Alene Mines Corporation
505 Front Avenue
Coeur d’Alene, Idaho 83814

 Re: Coeur d’Alene Mines Corporation
  Form 10 -K for Fiscal Year Ended December 31, 2011
  Filed February 23, 2012
  Response dated December 21, 2012
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your response  and 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 amending your filing, 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, or do not
believe an amendment is appropriate, please  tell us why in your response.

After reviewing any amendment t o your filing and the  information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

USA – Nevada -Rochester Mine, page 28

1. We note your response to comment 1 in which you discuss the status of your leased
claims, provided the requested supplemental information, and indicated you will revise
the stated number of leased claims to 66 claims.  Please include this discussion regarding
your leased claims in your modified filing, comment on any historical right of way’s, if
any, which facilitate access on your claims, and clarify that the 81 claims specified in
your lease agreements has been changed to the 66 claims as indicated in your response.
Should you intend to address this issue in future filings, please make the request for filing
prospectively and include your proposed modified paragraphs, sections, or pages with
your response.

Mr. Mitchell J.  Krebs
Coeur d’ Alene Mines Corporation
January 9, 201 3
Page 2

 2. We note you response to comment 2 in which you dis cuss the origin and effects of the
preliminary injunction boundary, but did not provide the requested map as you believe a
map of the preliminary injunction boundary is not material to investors.  We re -issue
comment 2.  Please include the preliminary inju nction map in your filing showing the
contested and uncontested mining claims, along with the website address for the map  in
your revised filing .

3. We note your response to comment 3 in which you respond that the mining operations at
your Rochester mine hav e not been affected by the disputed claim ownership, your leach
dumps and stockpile expansions are not affected, and that in the event an adverse
decision was rendered, the results could not be quantified.  Please include this discussion
in your modified f iling.

Year End Mineralized Material – Rochester Mine, page 30

4. We note your response to comment 6, in which you state the affected tonnage and grade
of mineralized material due the claim dispute and that you will include this estimate in
your future fili ngs.  Please revise your filing and include these estimates in your modified
filing .

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
45
Results  of Operations – Year Ended December 31, 2011 Compared to Year Ended December 31,
2010, page 56
Revenues, page 56

5. We note your response to our prior comment 7.  In accounting for gold production at
Palmarejo and Rochester mines as a by -product, please tel l us:
 how you account for gold inventory, including which costs are attributed to the gold
produced and how those costs are carried in inventory through production and
processing;
 whether your units -of-depletion calculations exclude gold reserves and gol d
production and how depletion would be impacted by their inclusion; and,
 an estimate of how co -product accounting would have impacted your cash cost per
ounce of silver and gold (or gold in silver -equivalent ounces) for 2011 and for the
nine months ended  September 30, 2012.

Notes to Consolidated Financial Statements , page F -8
Note 21 — Litigation and Other Events , page F -46
Unpatented Mining Claims Dispute at Rochester in Nevada, page F -47

6. We note your response to our prior comment 8 did not address all  aspects of our
comment.  In regards to the unpatented mining claims dispute at Rochester, please tell us

Mr. Mitchell J.  Krebs
Coeur d’ Alene Mines Corporation
January 9, 201 3
Page 3

 whether you believe the likelihood of a loss or impairment of assets is remote, reasonably
possible or probable pursuant to FASB ASC 450 -20 and the fa ctors your consider in
support of your conclusion.

 You may contact James Giugliano at (202) 551 -3319, or Brian K. Bhandari at (202) 551 -
3390, if you have questions regarding comments on the financial statements and related matters.
You may contact George  Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering comments.  Please contact me at (202) 551 -3871 with any other questions.

        Sincerely,

        /s/ Brian K. Bhandari for

        Tia L. Jenkins
Senior Assistant Chief Accountan t
Office of Beverages, App arel, and
Mining