SecProbe.io

November 18, 2011
 Via E-mail

Mr. Eric T. Jones Chief Financial Officer Thunder Mountain Gold, Inc. 5248 W. Chinden Blvd. Boise, Idaho 83714
Re: Thunder Mountain Gold, Inc.
 Form 10-K for the year ended December 31, 2010  Filed March 25, 2011
File No. 001-08429

Dear Mr. Jones:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 10-K for the Year Ended December 31, 2010

General

1. We note that your website refers to or us es the terms “measured,” “indicated,” or
“inferred,” resources.  If you continue to make references on your website or press
releases to reserve measures other than those recognized by the SEC, please accompany
such disclosure with cautionary la nguage comparable to the following:

Cautionary Note to U.S. Investors -The  United States Securities and Exchange
Commission permits U.S. mining companies,  in their filings with the SEC, to
disclose only those mineral deposits that a company can economically and legally extract or produce.  We use certain term s on this website, such as “measured,”
“indicated,” and “inferred”  “resources,” which the SEC guidelines generally
prohibit U.S. registered companies from in cluding in their filings with the SEC.

Mr. Eric T. Jones Thunder Mountain Gold, Inc. November 18, 2011 Page 2

 U.S. Investors are urged to consider cl osely the disclosure in our Form 10-K
which may be secured from us or the following website: http://www.sec.gov/edgar.shtml.

Tell us where you have positioned this cautionary language on your website.
 Item 2. – Description of Properties page 7

 2. We note you disclose histor ical resources and 43-101 co mpliant resources throughout
your filing.  The provisions in Instruction 3 to paragraph (b)(5) of Industry Guide 7
generally limit the disclosure of mineralizati on to proven and probable reserves in filings
with the SEC.  Therefore, as your location of  incorporation is Neva da, it appears that you
should remove all of the mineral resource di sclosures and associated values from your
filing as these do not constitute proven or probable reserves.
 3. Please disclose information regarding your  land and mineral rights for each of your
material properties.  If you have identified properties in your filing that are not material,
include a statement to that effect in your di sclosure and clarify your intentions.  For each
material property, include the following information:

 The nature of your ownership or  interest in the property.

 A description of all interest s in your properties, includi ng the terms of all underlying
agreements and royalties.

 An outline of the process by which mineral rights are acquired at the location, also
details concerning the basis of entitlem ent and duration of your mineral rights,
surface rights, mining claims or concessions.

 An indication of the type of rights or claims such as plac er or lode, exploration or
exploitation, State or Fede ral, patented or unpatent ed, lease or concession.

 Please include certain identif ying information, such as the property names, claim
numbers, grant numbers, mining concession na me or number, and dates of recording
and expiration that is sufficient to enable the claims to be distinguished from other
claims that may exist in th e area or your properties.

 The conditions that must be met to retain  your rights, claims or leases, including
quantification and timing of all necessary payments, including any annual
maintenance fees, also identifying the pa rty who is responsible for paying these
amounts.

 The area of your claims, either  in hectares or in acres.

Mr. Eric T. Jones Thunder Mountain Gold, Inc. November 18, 2011 Page 3

 Please ensure that you identify all material terms of the land or mineral rights securing
agreements to comply with paragraph (b)(2) of Industry Guide 7.
4. Please disclose the information required unde r paragraph (b) of Industry Guide 7 for all
material properties listed under this headi ng.  For any properties identified that are not
material, please include a statement to that effect, clarifying your intentions.  For each
material property, include the following information:

 The location and means of access to your  property, including the modes of
transportation utilized to and from the property.

 Any conditions that must be met in order to  obtain or retain title to the property,
whether you have surface and/or mineral rights.

 A brief description of the rock formations  and mineralization of  existing or potential
economic significance on the property.

 A description of any work completed on the property and its  present condition.

 The details as to modernization and physic al condition of the pl ant and equipment,
including subsurface improvements and equipment.

 A description of equipment, infr astructure, and other facilities.

 The current state of expl oration of the property.

 The total costs incurred to date and all planned future costs.

 The source of power and water that can be utilized at the property.

 If applicable, provide a clear statement th at the property is without known reserves
and the proposed program is exploratory in nature.

You may refer to Industry Guide 7, paragraphs  (b) (1) through (5), for specific guidance
pertaining to the foregoin g, available on our website at the following address:
www.sec.gov/about/forms/industryguides.pdf

 5. Please expand your disclosure concerning th e exploration plans for the properties as
required by section (b)(4)(i) of Industry Guid e 7.  The exploration plan should address
the following points:

 Disclose a brief geological justification for each of the exploration projects written in
non-technical language.

Mr. Eric T. Jones Thunder Mountain Gold, Inc. November 18, 2011 Page 4

  Give a breakdown of the exploration ti metable and budget, including estimated
amounts that will be required for each exploration activity, such as geophysics,
geochemistry, surface sampling, dr illing, etc. for each prospect.

 If there is a phased program pla nned, briefly outline all phases.

 If there are no current detailed plans to conduct exploration on th e property, disclose
this prominently.

 Disclose how the exploration program will be funded.

 Identify who will be conducting any proposed exploration work and disclose their
qualifications.
 6. In an appropriate location of your filing please provide a short summary of the permits
and/or operational plans requi red to perform exploration, development, and production
activities on your properties.  We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 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 federa l securities laws of  the United States.

You may contact John Coleman at (202) 551- 3610 with questions about engineering
comments.  Please contact me at (202) 551-3871 with any other questions.
Sincerely,  /s/Tia L. Jenkins  Tia L. Jenkins Senior Assistant Chief Accountant

Mr. Eric T. Jones Thunder Mountain Gold, Inc. November 18, 2011 Page 5