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CORRESP
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CORRESP

 February 20, 2013

 VIA EDGAR AND HAND DELIVERY

 Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

 Office of
Beverages, Apparel, and Mining

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
Coeur d’Alene Mines Corporation

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

 Filed
February 23, 2012

 Comment Letter dated February 6, 2013

File No. 001-08641

Dear Ms. Jenkins:

 On
behalf of Coeur d’Alene Mines Corporation Inc. (the “Company”), this letter responds to your letter, dated February 6, 2013 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10-K
(the “Annual Report”), filed on February 23, 2012. The comment of the Staff of the Division of Corporation Finance (the “Staff”) is set forth below, followed by the Company’s response. For ease of
reference, the headings and numbered paragraph below correspond to the headings and numbered comment in the Comment Letter. The response of the Company is set forth in ordinary type beneath the comment of the Staff appearing in bold type.

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

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 45

 Reconciliation of Non-GAAP Cash Costs to GAAP Production Costs, page 53

1.
 We note your response to our prior comment 5. We also note the significant effect of by-product credits to your silver cost per ounce and cash cost
per ounce measures computed using gold as a by-product. Accordingly, please modify your computation of these measures for the Palmarejo and Rochester mines so as not to include gold

as a by-product credit. Please also expand your disclosure to include the significant assumptions underlying your computation. In your response, tell us how you intend to present these measures
in future filings.

 Answer:

 The Company plans to file its next Form 10-K on or around February 21, 2013. The Company believes that continued presentation of cash costs per ounce including a by-product credit is useful to
readers of the financial statements for consistency and comparability purposes. The Company proposes to include substantially the following disclosure in its next Form 10-K and future Forms 10-K for the Palmarejo and Rochester mines as supplemental
disclosure to our by-product presentation of cash operating and total cash costs per ounce:

 “The low costs per silver
ounce are due in part to significant by-product credits from gold production and an increase in price over the last three years. For the years ended December 31, 20XX, 20XX and 20XX, gold by-product credits were approximately $XX.XX, $XX.XX and
$XX.XX per silver ounce, respectively, and were deducted from operating costs in the calculation of cash costs per ounce. If our accounting policy had been changed to treat gold production as a co-product, the following total cash costs per ounce
would have been reported:

20XX

20XX

20XX

 Cash operating cost per ounce:

 Silver

$
XX.XX

$
XX.XX

$
XX.XX

 Gold

$
 XXX

$
 XXX

$
 XXX

 Total cash cost per ounce:

 Silver

$
XX.XX

$
XX.XX

$
XX.XX

 Gold

$
 XXX

$
 XXX

$
 XXX”

 Further, the Company proposes to include substantially the following disclosure in its next Form 10-K and
future Forms 10-K to assist with the reconciliation of Non-GAAP cash costs per ounce to GAAP production costs on both a by-product and co-product basis:

 “Gold is accounted for as a by-product credit at the Palmarejo and Rochester mines whereby revenues from gold are deducted from operating costs in the calculation of cash costs per ounce. If our
accounting policy was changed to treat gold as a co-product, the following costs per ounce would be reported:

Palmarejo

Rochester

 Total cash operating costs

$
XXX,XXX

$
XXX,XXX

 Total cash costs

$
XXX,XXX

$
XXX,XXX

 Revenue

 Silver

XX
%

XX
%

 Gold

XX
%

XX
%

 Ounces produced

 Silver

X,XXX,XXX

X,XXX,XXX

 Gold

XXX,XXX

XXX,XXX

 Total cash operating costs per ounce

 Silver

$
 XX.XX

$
 XX.XX

 Gold

$
 XXX

$
 XXX

 Total cash costs per ounce

 Silver

$
 XX.XX

$
 XX.XX

 Gold

$
 XXX

$
 XXX”

 *        *        *

 The Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in
the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the U.S. Securities and Exchange Commission (the “Commission”) from taking any action with respect to the filing 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.

If you have any questions regarding the above, please contact me at (208) 665-0770 or Andrew L. Fabens of Gibson, Dunn &
Crutcher LLP at (212) 351-4034. Please contact Elizabeth Druffel, the Company’s Treasurer and Chief Accountant, at (208) 665-0333 with regard to any accounting matters.

Very truly yours,

 /s/ Casey M. Nault

 Casey M. Nault

cc:
James Giugliano, Securities and Exchange Commission

Brian Bhandari, Securities and Exchange Commission

George Schuler, Securities and Exchange Commission

Mitchell J. Krebs, President and Chief Executive Officer

Frank L. Hanagarne, Jr., Senior Vice President, Chief Operating Officer and Chief Financial Officer

Donald J. Birak, Senior Vice President of Exploration

Elizabeth Druffel, Treasurer and Chief Accountant

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP