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     FOLEY & LARDNER LLP

     WASHINGTON HARBOUR

3000 K STREET, N.W., SUITE 500

WASHINGTON, D.C.  20007-5143

202.672.5300  TEL

202.672.5399  FAX

www.foley.com

     March 9, 2006

     WRITER'S DIRECT LINE

202.295.4003

abill@foley.com  Email

     CLIENT/MATTER NUMBER

302010-0001

Ms. Jill S.
Davis
Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance

Mail Stop 7010
Washington, DC 20549

Re:
Coeur
d’Alene Mines Corporation
Item 4.02 Form 8-K
Filed March 2, 2006
File No. 1-8641

Dear Ms. Davis:

        We
are writing on behalf of Coeur d’Alene Mines Corporation (“Coeur” or the
“Company”) in response to the Staff’s letter of comments, dated March 7,
2006, regarding the Company’s Current Report on Form 8-K, filed March 2, 2006. Set
forth below are the comments contained in your letter and the Company’s responses
thereto.

Item 4.02 Form 8-K filed
March 2, 2006

1.
Please
tell us if your certifying officers have reconsidered the effect on the
          adequacy of your disclosure controls and procedures as of the end of the period
          covered by your Form 10-Q for the quarter ended March 31, 2005 in light of
          the error you have disclosed. Additionally, tell us what effect the error had
on           your current evaluation of disclosure controls and procedures as of your
fiscal           year ended December 31, 2005.

Response:

The
error was identified in connection with the 2005 year-end audit and was the result of an
inadvertent miscalculation of the quantity of ore tons delivered to the Company’s
Rochester Leach Pad in January 2005. The error resulted in a quarter-end inventory
understatement, an overstatement of production costs applicable to sales and an
overstatement of the net loss for the first quarter of 2005 in the amount of $625,000.
During the course of 2005, as a part of the Company’s SOX 404 deficiency remediation
process, the Company enhanced its control procedures at its operating units,
including requiring a completion of standard reporting packages for all significant
financial accounts. These financial reporting packages are reviewed by the Company’s
Assistant Controller and its Controller who double check the detail account
reconciliations and calculations related to the leach pad inventory. These new controls
would have detected the error had they been in place in the first quarter of 2005. Those
procedures were in place for all quarters subsequent to the first quarter of 2005 and
were tested and found to be functioning effectively. As a result, these controls were
deemed to have remediated the material weakness existing at March 31, 2005. Accordingly,
the Form 10-K for the year ended December 31, 2005, which we plan to file as soon as
practicable, will report under Item 9A that the certifying officers concluded that the
Company’s disclosure controls and procedures as of December 31, 2005 were effective.

BOSTON

BRUSSELS

CHICAGO

DETROIT

JACKSONVILLE

LOS ANGELES

MADISON

MILWAUKEE

NEW YORK

ORLANDO

SACRAMENTO

SAN DIEGO

SAN DIEGO/DEL MAR

SAN FRANCISCO

SILICON VALLEY

TALLAHASSEE

TAMPA

TOKYO

WASHINGTON, D.C.

WEST PALM BEACH

Ms. Jill S. Davis
U.S.
Securities and Exchange Commission
March 9, 2006
Page 2

The
Company’s certifying officers have reconsidered the effect of the adequacy of the
Company’s disclosure controls and procedures as of March 31, 2005 in light of the
adjustment that was reported in the Form 8-K. As explained in response to the Staff’s
next comment, the Company will file an amended Form 10-Q to restate the financial
statements for the first quarter of 2005. The Form 10-Q/A will report under Item 4 as a
result of the miscalculation that the Company’s certifying officers have concluded
that the Company’s disclosure controls and procedures were not effective as of March
31, 2005.

2.
Please
support your conclusion that you should not file an amended Form 10-Q for           the
quarter ended March 31, 2005 given your disclosure that “the interim
          financial statements previously set forth in the Company’s Quarterly
Report           on Form 10-Q for the quarter ended March 31, 2005 should no longer
be           relied upon.”

Response:

The
Company is filing an amendment to the Form 10-Q for the quarter ended March 31, 2005,
which will include restated financial statements for the quarter. Previously, the Company
had planned to include restated quarterly financial data in a footnote to the financial
statements in its Form 10-K for the year ended December 31, 2005. However, the Company
has now concluded that it will file a Form 10-Q/A
to set forth restated financial statements for the first quarter of 2005. Clean and marked copies
of the amendment will be delivered to the Staff at the time of filing to expedite its
review.

        In
connection with the Company’s responses set forth above, attached hereto is a
statement from the Company acknowledging that: (i) the Company is responsible for the
adequacy and accuracy of the disclosure in the above-referenced filing on Form 8-K; (ii)
Staff comments or changes to disclosure in response to Staff comments do not foreclose the
Commission from taking any action with respect to the above-referenced Form 8-K; and (iii)
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.

        Prior
to receiving your letter dated March 7, the Company had taken steps to proceed early next
week with an offering of common stock under its shelf Registration Statement. Accordingly,
we would greatly appreciate your prompt attention and assistance in the resolution of
this matter so that the offering can go forward early next week as previously planned.

Ms. Jill S. Davis
U.S.
Securities and Exchange Commission
March 9, 2006
Page 3

        Please
convey any comments or questions you have regarding the above to the undersigned at
202-295-4003 or Jay W. Freedman of this firm at 202-295-4008.

Sincerely,

/s/ Arthur H. Bill

Arthur H. Bill

cc:
Ms.
Jennifer Goeken

March 7, 2006

Ms. Jill S. Davis
Branch
Chief
United States Securities and Exchange Commission
100 F Street NE
Washington, DC
20549-7410

Re:
Coeur
d’Alene Mines Corporation
Item 4.02 Form 8-K
Filed March 2, 2006
File No. 1-8641

Dear Ms. Davis:

        In
response to your comment letter dated March 7, 2006, regarding the above Form 8-K of Coeur
d’Alene Mines Corporation (the “Company”), we acknowledge that:

•
the
Company is responsible for the adequacy and accuracy of the disclosures in the filing;

•
SEC
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.

Yours truly,

/s/ Dennis E. Wheeler

Dennis E. Wheeler
Chairman, President
and CEO

/s/ James A. Sabala

James A. Sabala
Executive Vice
President and CFO