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CORRESP
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February 3, 2023

Via EDGAR

Division of Corporation Finance

Office of Energy and Transportation

U.S. Securities and Exchange Commission

100 F Street, NE

Washington DC 20549

Attention: Craig Arakawa, Accounting Branch Chief

  George K. Schuler, Mine Engineer

  Steve Lo, Staff Accountant

Re: McEwen Mining Inc.

Form 10-K for the Fiscal Year Ended December 31,
2021

Filed March 7, 2022

Form 10-Q for the Quarter Ended September 30,
2022

Filed on November 4, 2022

File No. 001-33190

Dear Messrs. Arakawa, Schuler and Lo:

We refer to your correspondence dated December 20,
2022, addressed to Perry Ing, Chief Financial Officer of McEwen Mining Inc. (“McEwen Mining”, the “Company” or
 “we”), relating to the Company’s Annual Report on Form 10-K for the year ended December 31, 2021 and the Company’s
Quarterly Report on Form 10-Q for the quarter ended September 30, 2022.

The Company’s responses are as follows:

Form 10-K for the Year Ended December 31,
2021

Gold Bar Mine, page 35

Comment No. 1

Please modify your filing to provide a brief
description of your property/mineral rights for all your material properties as required by Item 1304(b)(1)(iii) of Regulation S-K.

Response

As discussed on the Company’s telephone
call with the Securities and Exchange Commission’s staff (“Staff”) on January 27, 2023, with respect to our mineral
rights in the United States, we describe our material Gold Bar Mine and Tonkin Properties on pages 33 to 35, including the names,
numbers and sizes of our claims listed in tabular format on page 33, in compliance with the requirements in Item 1304(b)(1)(iii) of
Regulation S-K.

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 2

Black Fox Mine, page 37

Comment No. 2

We note your Black Fox properties is not
located using a common coordinate system. Please modify your filing and locate all your material properties to be within 1-mile using
a common coordinate system. See Item 1304(b)(1)(i) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Form 10-K filings to add location information using a
common coordinate system for all material properties, in order to comply with Item 1304(b)(1)(i) of Regulation S-K, beginning with
its Form 10-K for the fiscal year ended December 31, 2022.

Specifically, the Company intends to revise its
disclosure as follows:

The Black Fox and Froome Mines are located 6 miles
east of Matheson, Ontario, and accessed directly from Highway 101 East. Matheson, in turn, is located approximately 45 miles from Timmins,
which has a commercial airport. Timmins is approximately 342 miles north of Toronto by air. The approximate coordinates for the
geographic center of the Black Fox and Froome Mines are N48°32'2" and W80°20'2".

The Stock Mill is located approximately 17 miles
from the Black Fox and Froome Mines. Mineralized material is shipped to the mill from the Froome Mine by truck. The approximate
coordinates for the geographic center of the Stock Mill is N48°33'0" and W80°45'1".

Exhibit 96.1 San Jose

Mineral Resource Estimate, page ES-18

Comment No. 3

We note you have disclosed your resources
inclusive of reserves in this section. Please modify your filing to provide a similar tabulation of your resources exclusive of reserves
as required by Instruction 2 to Paragraph 601(b)(96)(iii)(B)(11) of Regulation S-K.

Response

As discussed on the Company’s telephone
call with the Staff on January 27, 2023, footnote 2 of the Mineral Resource Estimate on page ES-18 indicates that the mineral
resource estimate is disclosed exclusive of mineral reserves in compliance with Instruction 2 to Item 601(b)(96)(iii)(B)(11) of Regulation
S-K.

Product Pricing, page ES-184

Comment No. 4

We note you base your commodity price on
consensus pricing. Please modify your filing to describe the basis of this consensus pricing, listing the financial institutions that
provided the forecasts and the dates these forecasts were released. See Item 601(b)(96)(iii)(B)(16)(i) of Regulation S-K.

Response

As discussed on the Company’s telephone
call with the Staff on January 27, 2023, the basis of the commodity price consensus pricing was provided by S&P Global Market
Intelligence Metals and Mining with an effective date of November 30, 2020 and disclosed on page ES-184 as part of Table 16-1
Gold and Silver Price Forecast, in compliance with Item 601(b)(96)(iii)(B)(16)(i) of Regulation S-K.

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 3

Mine Closure Plan, page ES-194

Comment No. 5

Please modify your report to provide your
QP’s opinion on the adequacy of your environmental plans as required by Item 601(b)(96)(iii)(B)(17)(iv) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add an explicit statement of adequacy of our environmental plans as required by Item 601(b)(96)(iii)(B)(17)(vi) of Regulation
S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Qualified Person’s Opinion on Adequacy
of Current Plans to Address Issues

Based on the information provided to the QP by
the Company, there are no material issues known to the QP. The San José operations are mature mining operations and currently have
the approval to operate within its local communities.

Capital and Operating Costs, page ES-195

Comment No. 6

Please modify your report to define the
accuracy of your capital and operating costs estimates as required by Item 601(b)(96)(iii)(B)(18)(i) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add a statement to define accuracy of our capital and operating cost estimates, as required by Item 601(b)(96)(iii)(B)(18)(i) of
Regulation S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Capital and operating costs at San José
have been estimated to an accuracy of +/- 10% to 15%.

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 4

Economic Analysis, page ES-205

Comment No. 7

Please modify your report to provide additional
line items supplementing your annual production by including your recovered and salable product quantities which generate your revenues,
with text describing this calculation as required by Item 601(b)(96)(iii)(B)(19) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add line items supplementing our annual production by including our recovered and salable product quantities which generate
our revenues, including text describing this calculation as required by Item 601(b)(96)(iii)(B)(19) of Regulation S-K.

An example of the intended revision is included
in Appendix A to this letter.

Exhibit 96.2 Los Azules

Mineral Resource Estimate, Section 1.4,
page ET-1

Comment No. 8

We note you have disclosed your resources
inclusive of reserves in this section. Please modify your report to provide a similar tabulation of your resources exclusive of reserves
as required by Instruction 2 to Paragraph 601(b)(96)(iii)(B)(11) of Regulation S-K.

Response

As discussed on the Company’s telephone
call with the Staff on January 27, 2023, footnote 1 of the Mineral Resource Estimate on page ET-1 indicates that the mineral
resource estimate is disclosed exclusive of mineral reserves in compliance with Instruction 2 to Item 601(b)(96)(iii)(B)(11) of Regulation
S-K.

Mineral Process and Metallurgical testing,
Section 12, page ET-12

Comment No. 9

Please modify your report to provide your
QP’s opinion on the adequacy of your metallurgical data as required by Item 601(b)(96)(iii)(B)(10)(v) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add an explicit statement of adequacy of our metallurgical data as required by Item 601(b)(96)(iii)(B)(10)(v) of Regulation
S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 5

Qualified Person’s Opinion on Data Adequacy

In the opinion of the QP, the metallurgical test
work and reconciliation and production data support the metallurgical assumptions used in the mineral resources, the mine plans and the
economic analysis.

Economic Analysis, Section 19, page ET-19

Comment No. 10

Please provide numerical values for your
annual cash flow, including your annual production, salable product quantities, revenues, major cost centers, taxes and royalties, capital,
and final closure costs. See Item 601(b)(96)(iii)(b)(19) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add numerical values for annual cash flow, including annual production, salable product quantities, revenues, major cost centers,
taxes and royalties, capital and final closure costs as required by Item 601(b)(96)(iii)(B)(19) of Regulation S-K.

An example of the intended revision is included
in Appendix B to this letter.

Exhibit 96.3 Gold Bar

Gold Bar Recovery Projection, page EU-127

Comment No. 11

Please modify your report to provide your
QP’s opinion on the adequacy of your metallurgical data as required by Item 601(b)(96)(iii)(B)(10)(v) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add an explicit statement of adequacy of our metallurgical data as required by Item 601(b)(96)(iii)(B)(10)(v) of Regulation
S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Qualified Person’s Opinion on Data Adequacy

In the opinion of the QP, the metallurgical test
work and reconciliation and production data support the metallurgical assumptions used in the mineral resources, the mine plans and the
economic analysis.

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 6

Mine Production Schedule, page EU-207

Comment No. 12

Please provide annual numerical values for
your life of mine production schedule. This would include annual processed ore with associated grades for the life of mine. See Item 601(b)(96)(iii)(b)(13)
of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add annual numerical values for our life of mine production schedules, including annual processed ore with associated grades
for the life of mine as required by Item 601(b)(96)(iii)(B)(13) of Regulation S-K.

An example of the intended revision is included
in Appendix C to this letter.

Capital and Operating Costs, page EU-236

Comment No. 13

Please modify your report to define the
accuracy of your capital and operating costs estimates as required by Item 601(b)(96)(iii)(B)(18)(i) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add a statement to define accuracy of our capital and operating cost estimates, as required by Item 601(b)(96)(iii)(B)(18)(i) of
Regulation S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Capital and operating costs at Gold Bar have been
estimated to an accuracy of +/- 10% to 15%.

Net Present Value, page EU-240

Comment No. 14

Please provide numerical values for your
annual cash flow, including your annual production, salable product quantities, revenues, major cost centers, taxes and royalties, capital,
and final closure costs. See Item 601(b)(96)(iii)(b)(19) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add numerical values for annual cash flow, including annual production, salable product quantities, revenues, major cost centers,
taxes and royalties, capital and final closure costs as required by Item 601(b)(96)(iii)(B)(19) of Regulation S-K.

An example of the intended revision is included
in Appendix D to this letter.

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 7

Exhibit 96.4 Fox Complex

Recoveries, page EV-10

Comment No. 15

Please modify your report to provide your
QP’s opinion on the adequacy of your metallurgical data as required by Item 601(b)(96)(iii)(B)(10)(v) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add an explicit statement of adequacy of our metallurgical data as required by Item 601(b)(96)(iii)(B)(10)(v) of Regulation
S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Qualified Person’s Opinion on Data Adequacy

In the opinion of the QP, the metallurgical test
work and reconciliation and production data support the metallurgical assumptions used in the mineral resources, the mine plans and the
economic analysis.

Preliminary Closure Planning, page EV-17

Comment No. 16

Please modify your report to provide your
QP’s opinion on the adequacy of your environmental plans as required by Item 601(b)(96)(iii)(B)(17)(iv) of Regulation S-K.

Response

As discussed on its telephone call with the Staff
on January 27, 2023, the Company will revise its disclosures in future Technical Report Summaries included with its Form 10-K
filings to add an explicit statement of adequacy of our environmental plans as required by Item 601(b)(96)(iii)(B)(17)(vi) of Regulation
S-K, beginning with its Form 10-K for the fiscal year ended December 31, 2022.

As an example, the Company intends to revise its
disclosure as follows:

Qualified Person’s Opinion on Adequacy
of Current Plans to Address Issues

Based on the information provided to the QP by
the Company, there are no material issues known to the QP. The Fox Complex operations are mature mining operations and currently have
the approval to operate within its local communities.

Division of Corporation Finance

U.S. Securities and Exchange Commission

Attention: Mr. Craig Arakawa

February 3, 2023

Page 8

Form 10-Q for the Quarter Ended September 30,
2022

Note 4 Other Income, page 10

Comment No. 17

We note your disclosure related to the gain
recognized on your