SecProbe.io

November 6, 2014

Via E -Mail
Mr. Mitchell J.  Krebs
Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Avenue, Suite 900
Chicago, IL 60603

 Re: Coeur Mining, Inc.
  Form 10 -K for the Year Ended December 31, 2013
  Filed February 26, 2014
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your filing s 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  providing the requested
informatio n 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 the  Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition  and Results of Operations, page
31
Critical Accounting Policies and Developments – Impairments, page 33

1. We note your disclosure under Note 4 that you recorded an impairment charge of
$773 million to mining properties in 2013.  Considering your impairment charges
and significant decline in your realized silver and gold prices during the periods
reported, to e nhance investor’s understanding regarding your recent impairment
testing of long lived assets, please confirm that you will disclose the following in
future filings:

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 2

  the amount of long -lived assets (mineral interests and property, plant and equipment)
allocated to each of the asset groups that are at risk of impairment and the percentage
by which fair value exceeded carrying value as of the date of the most recent test;

 a description of the methods and key assumptions used and how the key assumptions
were  determined;

 a discussion of the degree of uncertainty associated with the key assumptions  in as
specific a manner as p racticable ;

 the factors that affect variabi lity in the pricing assumptions ; and,

 a description of potential events and/or changes in circumstances that could
reasonably be expected to negatively affect the key assumptions.

Please provide us with a draft of your proposed disclosures.  Refer to FR -72, which can
be found on our website at : http://www.sec.gov/rules/interp/33 -8350.htm.

Liquidity and Capital Resources, page 40
Cash provided by operating activities, page 40

2. We note significant changes in your cash flows from operating activities during the
periods presented , for example, c ash provi ded by operating activities decreased by
$145 million and $158 million during 2012 and 2013 , respectively.  We note that
you have provided a general discussion for the reasons for the change.   However,
your discussions did not clearly identify the specific quantitative effect of the
underlying causal factors responsible for the change.  To enhance an investor’s
understanding, please confirm that in future filings you will include robust
discussions describing and quantifying the specific effect of the si gnificant drivers
that contributed to the material changes in your operating cash flows.  Please provide
us with a draft of proposed disclosures to be included in future filings.  Refer to Item
303 of Regulation S -K and SEC Release No. 33 -8350 as it relate s to liquidity and
capital resources for further guidance.

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 3

 Overview of Mining Properties and Interests, page 3
Business Strategy and Compet itive Strengths, page 8
Risk Factors, page 13 and 14
Argentina — Joaquin Mine, page 23 and 24
Looking Forward, page 32
Foreign Currency Contracts and Hedges, page 48
Note 1 0 – Acquisitions, page F -23

3. We note you  refer to the Joaquin and the La Preciosa  properties as development
stage properties at the above locations and elsewhere in your filing.  The terms
development and production have very specific meanings within Industry Guide 7
(see www.sec.gov/about/forms/industryguides.pdf).  These words/terms reference
the development stage when preparing reserves for production, and the production
stage when companies are engaged in commercial -scale, profit -oriented extraction of
minerals.  Since you do not disclose any reserves for these properties, as define d by
Guide 7, please remove the terms develop, development or production throughout
your document, and replace this terminology, as needed, with the terms such as
explore or exploration.

4. We note your royalty properties, Cerro Bayo, El Gallo/Magistral, and  Zaruma are
properties with reserves or mineralized materials that are not disclosed or updated in
your filing.  Please modify your filing and provide updated reserve/mineralized
material estimates for all your royalty properties, ideally to coincide with your fiscal
year end.

5. A portion of your revenues is dependent on the mine production that occurs at your
royalty properties, but we note you do not report the silver or the funds received, nor
do your report the tonnage and grade mined and/or processed at  these respective
properties, nor do your report the sal eable metals on which your royalty revenues are
based.  Please revise your filing to include detailed production information, sal eable
metals, and revenues received for each of your royalty properties.

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 4

 Form 8 -K filed June 23, 2014

Exhibit 99.1 – Press release dated June 23, 2014
Gold Stream Agreement with Franco -Nevada

6. You disclose that under the new gold stream agreement, the gold payable to Franco -
Nevada would be recorded as a reduction in revenue r ather than in costs applicable
to sales.  Please provide us with a summary analysis of the terms of the two
agreements and your basis for the difference in recognition (reduction in revenue
versus cost) and the specific accounting literature that supports your position.

Form 10 -Q for the Quarter Ended June 30, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
31
Highlights – Three months ended June 30, 2014, page 31

7. We note your disclosure regarding your decision to defer development at La
Preciosa.  Please address the following:

 Tell us whether you considered this decision or the results of the updated feasibility
study to be a triggering event for assessing impairm ent at June 30, 2014 and explain
the basis for your conclusion.  Please refer to FASB ASC 360 -10-35-21.

 Please expand your critical accounting policy disclosure in future filings to include
your impairment assessment and triggering event considerations su rrounding La
Preciosa’s deferment decision.   Considering the significant decline in your realized
silver and gold prices, to the extent La Preciosa is considered to be at risk of
impairment, disclose the results of impairment testing, methodology, significant
estimates and underlying assumptions.  Please provide us with a draft of proposed
disclosures to be included in future filings.

 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 information 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 disclosures they have made.

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 5

  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

 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.

 You may contact James Giugliano at (202) 551 -3319, or Raj Rajan at (202) 551 -3388, if
you have questions regarding comments on the financial statements and related matters.  You
may conta ct George Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering comments.

        Sincerely,

        /s/Tia L. Jenkins

        Tia L. Jenkins
        Senior Assistant Chief Accountant
Office of Beverages, Apparel, and
Mining