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CORRESP
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     Mitchell J. Krebs

     Senior Vice President and

     Chief Financial Officer

May 14, 2008

Mr. H. Roger
Schwall
Assistant Director
U.S.           Securities and Exchange Commission
Division of
Corporate Finance
100 F Street,           N.E.
Mail Stop 7010
Washington, DC 20549

RE:
Coeur
d’Alene Mines Corporation
Form 10-K for Fiscal Year ended December 31, 2007
Filed
February 29, 2008
Schedule 14A Filed April 1, 2008
File No. 1-08641

Dear Mr. Schwall,

        I
am writing on behalf of Coeur d’Alene Mines Corporation (“Coeur” or the
“Company”) in response to the Staff’s letter of comments, dated April 30,
2008, regarding the Company’s Annual Report on Form 10-K for the year ended December
31, 2007 (the “Form 10-K”) which was filed on February 29, 2008, and Schedule
14A (the “Proxy”) which was filed on April 1, 2008. Set forth below are the
comments contained in your letter and the Company’s responses thereto.

        Your
attention is directed to the Company’s Form 10-Q for the quarter ended March 31, 2008
filed on May 12, 2008 (the “Form 10-Q”) which addresses certain of those
comments as noted below.

        Underlined
text indicates new disclosure added to address certain of the Staff’s comments.

Coeur d’Alene Mines
Corporation
505 Front Avenue, P.O. Box I
Coeur d’Alene, Idaho 83816-0316
Telephone
208.667.3511
Facsimile 208.667.2213
www.coeur.com

Form 10-K for Fiscal Year
Ended December 31, 2007

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

General

1.
Please
expand your discussion under this heading to include a meaningful           introduction
or overview. In this regard, we refer you to the Commission           Guidance Regarding
Management’s Discussion and Analysis of Financial           Condition and Results of
Operations (Release No. 34-48960). As examples only, if           material, discuss the
impact on future results of the possible sale of the           Rochester mine, the delay
in obtaining a permit for the tailings disposal           facility for the Kensington
mine, the increased costs and decreased production           at Cerro Bayo, and the
capital expenditures necessary to bring the Palmarejo           project into production
and the resulting impact on liquidity.

Response:

        Disclosure
in response to this comment was included in the Company’s MD&A in the Form 10-Q
for the quarter ended March 31, 2008 that was filed on May 12, 2008. Similar disclosures
also will be included in the MD&A section of the Company’s future Forms 10-K and
10-Q.

Insert
to 3/31/08 Form 10-Q:

        The
Company’s business strategy is to capitalize on the ore reserve/mineralized material
bases located at its operating mines and the expertise of its management team to continue
as a leading primary silver production company through long-term, cash flow generating
growth. The principal elements of the Company’s business strategy are to: (i) increase
the Company’s silver production and reserves; (ii) decrease cash costs and
increase production at the Company’s existing silver mining operations; (iii) transform
development-stage properties into producing mines; (iv) acquire operating mines,
mineral interests and exploration and/or development properties with a view to reducing
the Company’s cash and total costs, providing short-term positive cash flow return
and expanding its silver production base and reserves; and (v) continue to explore
for new silver and gold discoveries primarily near its existing mine sites and evaluate
new opportunities to expand its production through acquisitions and exploration.

        In
addition to the matters discussed above with respect to the key factors of the Company’s
business strategy, the most important matters with which management is concerned in
evaluating the Company’s financial condition and results of operations include:

•
Rochester
Mine. As scheduled, mining activities at Rochester ceased in August 2007 as the mine
entered its residual leaching  phase, which is expected to continue through 2011. The
Company continues to explore its options with respect to   this property, including a
potential sale of the property and possible follow-up activities related to any favorable
 results from the Company’s exploration program conducted in the district during
2007. The reduced production being   experienced in the residual leaching stage, and
ultimate cessation of activities there, will result in a reduction  in net sales.

•
Kensington
Mine. The Company continues to achieve major milestones in its effort to
enable the Kensington Mine to commence  production, including the completion of
Kensington’s mill, related surface facilities and a tunnel connecting the  Kensington
and Jualin properties. In addition, the Company continues to cooperate with environmental
conservation  groups with respect to the use of an alternative site for the
construction of the mine’s tailings disposal  facility. Further delay in the
commencement of production at the Kensington Mine would adversely affect the  Company’s
costs and liquidity.

•
Cerro
Bayo Mine. The Company’s top priority with respect to this mine is to
reduce operating costs and increase gold and  silver production. As part of the
ongoing operational improvement program at the Cerro Bayo mine, in April 2008,  the
Company announced a temporary suspension of mining operations at this mine, expected to
last approximately six  weeks, in order to upgrade its electrical infrastructure.
On May 5, 2008, the Company announced that the mine had  resumed operations ahead
of schedule. The continued successful implementation of the improvement program of Cerro
 Bayo will be key to achieving the Company’s goals of reducing costs and
increasing production at this mine.

•
Palmarejo.
In December 2007, Coeur completed the acquisition of the Palmarejo project. Capital
expenditures for this property are currently estimated to be approximately $225
million and construction activities there are already underway. The Company
currently expects to commence commercial production during the first half of 2009. Any
significant increase in the capital expenditures and/or delay in the commencement
of production would adversely affect the Company’s costs and liquidity.

•
San
Bartolome. The Company expects to commence commercial production at its open
pit silver development property in Bolivia  in the second quarter of 2008, and
estimates that initial full scale operating costs will approximate $4.10 per  ounce,
excluding royalties and production taxes. Other uncertainties associated with the project
include the  estimated amount of mineralized material there and logistical and
other risks associated with mining in Bolivia.  If  there is a delay in the
expected commencement of commercial production, or if operating costs prove to be higher
 than now estimated, the Company’s results of operations will be adversely
affected.

Financial Statements

Note B-Summary of
Significant Accounting Policies
Revenue Recognition, page F-10

2.
Please
expand your disclosure to clarify whether or not you are presenting           revenues
and costs associated with silver sales transactions from the Endeavor           and
Broken Hill mines gross or net. If you are reporting these transactions on a
          gross basis, please provide us with a detailed analysis which explains why
these           transactions require gross reporting. Please include in your analysis,
without           limitation, the specific terms of each agreement, an explanation of why
you           believe you are the primary obligor, and why you believe you take
possession of           the metals produced from these mines at any point in the earnings
cycle. Please           refer to and address EITF 99-19 in your response.

Response:

        The
Company has modified its disclosure in response to this comment in the first quarter 2008
Form 10-Q that was filed on May 12, 2008, under Note B: Summary of Significant Accounting
Policies, Revenue Recognition (page 7), to clarify that we are presenting revenues and
production costs associated with silver sales transactions from Endeavor and Broken Hill
mines on a gross basis as set forth below:

        In
2005, the Company acquired all of the silver production and reserves up to a maximum of
20 million payable ounces, at the Endeavor mine and 17.2 million payable ounces at the
Broken Hill mine. Under the terms of the agreements, title in the contained silver passes
to Coeur immediately after the contained silver becomes severed from the ground. We
obtained legal opinions from reputable counsel opining that the contained silver to be
mined pursuant to the agreements constitutes silver reserves under SEC Industry Guide 7,
as the requisite conditions have been met, including the fact that the Company has the
requisite incidents of ownership. The legal opinions also provide that pursuant to
Australia’s Mining Act, the incidents of ownership possessed by Coeur through the
agreements are economically and legally equivalent to the incidents of ownership that
Coeur would possess over silver reserves at a property owned and mined by Coeur.
Consequently, we have concluded that the Company possesses silver reserves, acts as
principal obligor, and assumes the risks and rewards of ownership and, therefore, we are
appropriately including these reserves in our reserve disclosures and appropriately
reporting the sold amounts as gross revenues. Pursuant to agreements with the operators
of these two mines, the Company pays a fee to the operators designed to reimburse them
for the cost of mining Coeur’s silver reserves.

        As
owner of the silver ore reserves at these two mines, the Company includes the silver
reserves at the Endeavor and Broken Hill mines in the silver reserves disclosures
reported by Coeur. In addition, Coeur reports sales of its silver from the Endeavor and
Broken Hill mines in its “Sales of Metal” line item on the statement of
operations, includes the quantities in its reported silver production amounts, and
includes the quantities and related costs in its “cost per ounce” calculations
and reported amounts. In addition, the Company depletes the purchase price paid to
acquire the silver reserves at the Endeavor and Broken Hill mines over the life of the
reserves using the units of production depletion method.

        We
have not performed an assessment of the provisions of EITF 99-19 because the Company
possesses the requisite incidents of ownership of the contained silver (as outlined
above) and is appropriately accounting for sales of the silver outside the scope of EITF
99-19.

        The
updated disclosure reads as follows:

        Revenue
Recognition: Pursuant to guidance in Staff Accounting Bulletin (“SAB”) No.
104, “Revenue Recognition for  Financial Statements”, revenue is
recognized, net of treatment and refining charges, from a sale when persuasive evidence
of  an arrangement exists, delivery has occurred, the price is fixed or
determinable, no obligations remain and collectability is  probable. The passing of
title to the customer is based on the terms of the sales contract. Product pricing is
determined at the point revenue is recognized by reference to active and freely
traded commodity markets, for example the London Bullion  Market for both gold and
silver, in an identical form to the product sold.

        Under
our concentrate sales contracts with third-party smelters, final gold and silver prices
are set on a specified future quotational period, typically one to three months, after
the shipment date based on market metal prices. Revenues and production costs
applicable to sales are recorded on a gross basis under these contracts at the
time title passes to the buyer based on the forward price for the expected
settlement period. The contracts, in general, provide for a provisional payment
based upon provisional assays and quoted metal prices. Final settlement is based on the
average applicable price for a specified future period, and generally occurs from
three to six months after shipment. Final sales are settled using smelter weights,
settlement assays (average of assays exchanged and/or umpire assay results) and are
priced as specified in the smelter contract. The Company’s provisionally
priced sales contain an embedded derivative that is required to be separated from
the host contract for accounting purposes. The host contract is the receivable from the
sale of concentrates measured at the forward price at the time of sale. The
embedded derivative does not qualify for hedge accounting. The embedded derivative
is recorded as a derivative asset, in prepaid expenses and other assets or as a derivative
liability in accrued liabilities and other on the balance sheet and is adjusted to fair
value through revenue each period until the date of final gold and silver
settlement. The form of the material being sold, after deduction for smelting and
refining is in an identical form to that sold on the London Bullion Market. The form of
the product is metal in flotation concentrate, which is the final process for
which the Company is responsible.

        The
effects of forward sales contracts are reflected in revenue at the date the related
precious metals are  delivered or the contracts expire. Third party smelting and
refining costs of $2.4 million and $1.8 million during the three  months ended
March 31, 2008 and 2007, respectively, are recorded as a reduction of revenue.

        At
March 31, 2008, the Company had outstanding provisionally priced sales of $61.0 million,
consisting of 2.7  million ounces of silver and 18,800 ounces of gold, which had a
fair value of approximately $64.7 million including the  embedded derivative. For
each one cent per ounce change in realized silver price, revenue would vary (plus or
minus)  approximately $27,000 and for each one dollar per ounce change in realized
gold price, revenue would vary (plus or minus)  approximately $18,800. At March 31,
2007, the Company had outstanding provisionally priced sales of $51.4 million, consisting
 of 2.8 million ounces of silver and 23,000 ounces of gold, which had a fair value
of approximately $52.5 million including  the embedded derivative.

        Similar
disclosures also will be included in future Forms 10-K and 10-Q.

3.
Please
expand your disclosure to indicate whether or not the silver purchased           under
these contracts is reported as inventory on your balance sheet.

Response:

        Consistent
with our response to comment # 2, the Company has modified its disclosure in response to
this comment in the first quarter 2008 Form 10-Q that was filed on May 12, 2008, under
Note B-Summary of Significant Accounting Policies, Metal and Other Inventory, (page 9) to
clarify that we are reporting concentrate inventories associated with silver sales
transactions from Endeavor and Broken Hill mines when, as of the balance sheet date, ore
has been mined but not yet sold to a third party smelter. Similar disclosures will be
included in future Forms 10-K and 10-Q.

        The
disclosure reads as follows:

        Metal
and Other Inventory: Inventories include concentrate ore, dorè, ore in
stockpiles and operating materials and supplies. The classification of inventory
is determined by the stage at which the ore is in the production process. To the extent
there is work in process inventories at the Endeavor and Broken Hill mines, such amounts
will be carried as inventories. Inventories of ore in stock piles
are sampled for gold and silver content and are valued based on the lower of actual
costs incurred or estimated net realizable value based upon the period ending prices of
gold and silver. Material that does not contain a minimum quantity of gold and
silver to cover estimated processing expense to recover the contained gold and
silver is not classified as inventory and i