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corresp

June 23, 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

Response Letter Dated May 14, 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 June 12, 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 the Company’s response letter, dated May 14, 2008. Set forth below are the
comments contained in your letter and the Company’s responses thereto.

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

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

Financial Statements

Note B — Summary of Significant Accounting Policies

Metal and Other Inventory, page F-12

    1.

    We note your response to our prior comment number three. Please modify your disclosure to
indicate that the inventories associated with the Endeavor and Broken Hill mines are held by
third parties. Please quantify and present these inventories separately if material.

Mr. H. Roger Schwall

June 23, 2008

Page 2 of 8

    Response:

    Disclosure in response to this comment will be included in the second quarter 2008 Form 10-Q
to be filed no later than August 11, 2008, under Note B-Summary of Significant Accounting
Policies, Metal and Other Inventory, to clarify that the concentrate inventories associated
with silver sales transactions from the Endeavor and Broken Hill mines are held by third
parties. Concentrate inventories held by third parties associated with the Endeavor and
Broken Hill mines amounted to $175,000 and $165,000, respectively, at December 31, 2007 and
are included in the tabular disclosure in Note F as Concentrate and dorè inventory. Amounts
were deemed immaterial for separate disclosure. Similar disclosures will be included in
future Forms 10-K and Forms 10-Q, including separate disclosure of the dollar amounts if
they become material. The disclosure will read 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 is assigned no
value. All inventories are stated at the lower of cost or market, with cost being determined
using a weighted average cost method. Concentrate and dorè inventory includes product at the
mine site and product held by refineries and are also valued at lower of cost or market
value. Concentrate inventories associated with the Endeavor and Broken Hill mines are
held by third parties. Metal inventory costs include direct labor, materials,
depreciation, depletion and amortization as well as administrative overhead costs relating
to mining activities.

Operational Mining Properties, page F-12

    2.

    We note from your response to comment four from our letter dated April 30, 2008, that
drilling expenditures you incur at a producing mine to define and delineate residual mineral
deposits that have not been classified as proven and probable reserves are capitalized. As
there appears to be diversity in practice regarding the accounting treatment for such costs,
please expand your accounting policy disclosures to address the items below. In addition,
provide disclosure of the amounts that have been capitalized for the period and in total
relative to these costs for each period presented.

    •

    Expand your accounting policy for exploration and development costs to address the
criteria you use to determine whether or not a drilling expenditure represents an
exploration cost or a development cost.

    •

    Please indicate, if true, that your accounting for drilling costs depends upon
whether or not at the time the cost is incurred, the expenditure:

2

Mr. H. Roger Schwall

June 23, 2008

Page 3 of 8

    a.

    Embodies a probable future benefit that involves a capacity,
singly or in combination with other assets to contribute directly or indirectly
to future net cash inflows;

    b.

    You can obtain the benefit and control others access to it,
and,

    c.

    The transaction or event giving rise to your right to or
control of the benefit has already occurred.

    •

    Expand your accounting policy to explain how you determine whether or not you have
met the above criteria,

    •

    Clarify, if true, how the stage of mine development impacts whether or not
expenditure represents an asset.

    3.

    Your response to our prior comment number five remains unclear. Please clarify your
accounting for drilling and related costs incurred to identify additional resources, beyond
the boundaries of your known resources at your development or production stage properties.

    Response to #2 and #3:

    The Company will modify its disclosures in response to these comments in the second quarter
2008 Form 10-Q to be filed no later than August 11, 2008, under Note B-Summary of
Significant Accounting Policies, Operational Mining Properties and Mine Development, to
expand the disclosure of our accounting policy for drilling and related costs incurred to
update mineral resources to proven and probable reserves and our accounting treatment of
drilling and related costs incurred to identify additional resources at our development and
production stage properties.

    The disclosure will read as follows:

    Operational Mining Properties and Mine Development:

    Capitalization of mine development costs that meet the definition of an asset begins once
all operating permits have been secured, mineralization is classified as proven and probable
reserves and a final feasibility study has been completed. Mine development costs include
engineering and metallurgical studies, drilling and other related costs to delineate an ore
body, the removal of overburden to initially expose an ore body at open pit surface mines
and the building of access ways, shafts, lateral access, drifts, ramps and other
infrastructure at underground mines. Costs incurred during the start-up phase of a mine are
expensed as incurred. Costs incurred before mineralization is classified as

3

Mr. H. Roger Schwall

June 23, 2008

Page 4 of 8

    proven and probable reserves are expensed and classified as Exploration or Pre-development
expense. All capitalized costs are amortized using the units of production method over the
estimated life of the ore body based on recoverable ounces to be mined from proven and
probable reserves. Interest expense allocable to the cost of developing mining properties
and to construct new facilities is capitalized until assets are ready for their intended
use. Gains or losses from sales or retirements of assets are included in other income or
expense.

    Drilling and related costs incurred at our operating mines are expensed as incurred as
exploration expense, unless we can conclude with a high degree of confidence, prior to the
commencement of a drilling program, that the drilling costs will result in the conversion of
a mineral resource into proven and probable reserves. Our assessment is based on the
following factors: results from previous drill programs; results from geological models;
results from a mine scoping study confirming economic viability of the resource; and
preliminary estimates of mine inventory, ore grade, cash flow and mine life. In addition,
the Company must have all permitting and/or contractual requirements necessary to have the
right to and/or control of the future benefit from the targeted ore body. The costs of a
drilling program that meet these criteria are capitalized as mine development costs. All
other drilling and related costs, including those beyond the boundaries of the development
and production stage properties, are expensed as incurred.

    Drilling and related costs of approximately $xx and $xx, respectively, for the periods
presented met the criteria for capitalization listed above at our properties that are in the
production stage.

    The cost of removing overburden and waste materials to access the ore body at an open pit
mine prior to the production phase are referred to as “pre-stripping costs.” Pre-stripping
costs are capitalized during the development of an open pit mine. Stripping costs incurred
during the production phase of a mine are variable production costs that are included as a
component of inventory to be recognized in production costs applicable to sales in the same
period as the revenue from the sale of inventory.

Note E — Investments and Other Marketable Securities, page F-19

    4.

    We note your response to our prior comment number seven. Your representation of the
investment as of December 31, 2007 remains unclear. We further note your response indicates
the ABCP last traded in an active market on or about August, 13, 2007. We re-issue that
portion of our comment that requests you explain how you have classified (short-term vs.
long-term) the investment as of year end. Please provide support for your conclusions if you
are presenting this investment as a current asset at December 31, 2007.

4

Mr. H. Roger Schwall

June 23, 2008

Page 5 of 8

    Response:

    The Company has recorded the Asset-Backed Commercial Paper (“ABCP”) as a non-current asset
included in the “other” asset category on the Company’s consolidated balance sheet. This
classification as non-current is based on the timing of our intent and ability to utilize
those invested funds. The Montreal Proposal ABCP last traded in the active market on or
about August 13, 2007 and there are currently no market quotations available for the
Montreal Proposal ABCP. There is no certainty regarding the outcome of the Montreal Proposal
and therefore there is a significant amount of uncertainty in estimating the amount and
timing of cash flows associated with the Montreal Proposal ABCP. Accordingly, the Company
believes that the ABCP investment is appropriately recorded as a non-current asset.

    We note that the amounts for ABCP securities were not included in the table presentation of
the investments as of December 31, 2007 contained in Note E- Investments and Other
Marketable Securities. In future filings, the tabular disclosure of our investments will
include the ABCP amounts as non-current assets beginning with the second quarter 2008 Form
10-Q to be filed no later than August 11, 2008, and similar disclosures will be included in
future Forms 10-K and Forms 10-Q.

    The tabular disclosure will appear as follows:

    Gross

    Gross

    Unrealized

    Unrealized

    Estimated

    As of March 31, 2008:

    Cost

    Losses

    Gains

    Fair Value

    U.S. Corporate

    $
    2,000,000

    $
    —

    $
    —

    $
    2,000,000

    U.S. Government

    51,030,935

    —

    8,513

    51,039,448

    Total current
available for sale: Securities

    53,030,935

    —

    8,513

    53,039,448

    ABCP

    5,286,243

    —

    —

    5,286,243

    Equity Securities

    98,534

    355

    702,067

    800,247

    Total available for
sale securities

    $
    58,415,713

    $
    355

    $
    710,580

    $
    59,125,938

5

Mr. H. Roger Schwall

June 23, 2008

Page 6 of 8

Non-Producing and Development Properties, page F-23

    5.

    We note your response to our prior comment number nine. Please clarify for us the terms of
this policy. It remains unclear why this policy represents an asset beyond the period of
coverage. Your response indicates the policy provides coverage during the construction phase.
Please clarify if this policy is written for the entire construction phase or in shorter
increments. Also, please provide us with an understanding of your coverage, if any, during
the production phase.

    Response:

    The Company obtained a political risk insurance policy from Overseas Private Insurance
Corporation (“OPIC”) and another private insurer. The policy is in the amount of $155
million and covers 85% of any loss arising from expropriation, political violence or
currency inconvertibility. The coverage period started December 17, 2004 and extends
through December 16, 2024. The policy premiums are approximately $3.4 million per year. The
cost of this insurance policy is incremental to the Company’s other operations and is
directly related to the development, construction, and operation of the San Bartolome mine.
Therefore, consistent with our accounting policy of capitalizing direct and incremental
costs incurred during the development stage of our mines, we capitalized the costs of this
policy during the mine’s development stage; these costs represented the direct and
incremental cost of providing the necessary insurance coverage during that period. During
the production stage of the mine (which is expected to commence near the end of the second
quarter of 2008), the cost of this policy will be expensed as incurred.

Engineering Comments

    6.

    It appears that you are referring to the accommodation noted in Instruction 3 to paragraph
(b)(5) of Industry Guide 7, which is available to foreign companies and not to domestic
companies in your response to comment 12. The listing provisions of the Canadian and
Australian stock exchanges were developed by self regulated entities and as such are not
foreign law. Please modify your filing disclosure to remove your resource disclosures, and
ensure your disclosures of mineralized material do not include inferred resources.

    Response:

    Instruction 3 to paragraph (b)(5) of Industry Guide 7 states that:

    “Estimates other than proved (measured) or probable
(indicated) reserves . . . shall not be disclosed unless such information is required to be disclosed
by foreign or state law; provided, however, that where such estimates
previously have been provided to a person . . . that is offering . . . to
acquire the registrant’s securities, such estimates may be included.”

    Based on the above, mining resource data may be disclosed by Coeur if:

    •

    such data is required to be disclosed pursuant to foreign law; and/or

6

Mr. H. Roger Schwall

June 23, 2008

Page 7 of 8

    •

    such data previously has been disclosed by Coeur to another party that
offered to acquire Coeur’s securities.

    We respectfully submit that the plain English language contained in the above provision in
Guide 7 is not limited to foreign companies. It refers to “foreign or state law,” and has
no language supporting the proposition that the provision applies only to foreign companies.
(Indeed, inclusion of the word “state” in Instruction 3 makes even more clear what is
already clear — that the instruction applies to domestic corporations.)

    With respect to Canada, Coeur’s Canadian counsel has confirmed that Coeur is a reporting
issuer under the securities laws of the Canadian Provinces of Ontario, British Columbia and
Alberta (the “Canadian Securities Laws”), and is therefore subject to the requirements of
National Instrument 43-101, which has been adopted by each of those comm