SecProbe.io

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May 5, 2005

Via Facsimile (816) 472-0317 and U.S. Mail

David S. Miller
422 Armour Road
North Kansas City, Missouri 64116

RE:	Hecla Mining Company
      Preliminary Proxy Statement on Schedule 14A
      Filed by David S. Miller on April 29, 2005
File No. 01-08491

Dear Mr. Miller:

      We have the following comments on the above-referenced
filing.
Please note that we have listed illustrative examples; they are
only
examples provided to assist you in making changes throughout your
filing.

General

1. We understand that you have already sent definitive proxy
materials to shareholders, without properly filing your soliciting
materials with the SEC, and that certain security holders have
returned proxy cards to you.  Because it appears that those proxy
cards were solicited from shareholders in violation of the proxy
rules, we do not believe it is appropriate for you to use the
proxy
cards you received in response to your prior solicitation to vote
at
the upcoming annual meeting.  Please specifically advise
shareholders
that proxies previously solicited by you from holders of preferred
shares will not be voted.  Please further advise shareholders that
they must re-send a new proxy card and tell us how you intend to
distinguish between those proxy cards previously provided to you
and
those you are soliciting now.  We recommend that you arrange for
the
proxy cards to be printed in a color other than "white," the color
of
the company`s proxy card, in order to avoid confusion among
shareholders about the two different proxy cards.

2. Provide a discussion of your anticipated recourse if the proxy
solicitation is unsuccessful.

3. In future filings, please provide a cover page to the Schedule
14A
and the related disclosure.  Refer to Rule 14a-6(m).

4. We note that Hecla Mining Company filed additional definitive
materials on April 28, 2005 to announce the adjournment of the
annual
meeting until June 1, 2005.  Please revise your materials to
reflect
this change.

5. On a supplemental basis, advise us how the insurgent group was
formed.  Further, tell us who and how many shareholders you
contacted
with respect to this solicitation, the nature of these contacts
and
the content of your communications.  We may have further comment
upon
review of your response.

6. Characterize each statement or assertion of opinion or belief
as
such, and ensure that a reasonable basis for each opinion or
belief
exists.  Also refrain from making any insupportable statements.
Support for opinions or beliefs should be self-evident, disclosed
in
the proxy statement or provided to the staff on a supplemental
basis,
with a view toward disclosure, by submitting a Schedule 14A that
has
been annotated with support for each of the assertions made.  We
cite
the following examples of statements or assertions in the proxy
statement that, at a minimum, must be supported on a supplemental
basis or, at a maximum, require both supplemental support and
recharacterization as statements of belief or opinion:

* "[Hecla`s nominee directors`] ownership of common shares
provides
him with a financial incentive to favor the common shareholders at
the expense of the preferred shareholders," and
* "Both Mr. David Miller and Dr. Thomas Miller have experience in
running a company and working knowledge of financial statements."

These examples do not represent an exhaustive list of the
statements
that need to be amended and/or supported.  Furthermore, this
comment
should be considered in disseminating any future written
communications.

7. Please revise to indicate that the proxy statement and form of
proxy are preliminary copies.  Refer to Rule 14a-6(e)(1).

8. Please consider revising your proxy statement to clarify the
following:
* We note your reference to David S. Miller and Thomas G. Miller
as
"preferredholders" throughout the proxy statement.  Please
consider
revising this reference as it may confuse shareholders that you
represent all or some of Hecla`s preferred shareholders other than
yourselves.
* Please revise your references to "shareholders" and "shares" to
clarify that you are referring to holders of preferred stock and
preferred shares, as distinguished from holders of common stock
and
common shares.
* We note your references under "Voting Your Shares" and on the
proxy
card that you refer to the election of directors as "proposals."
As
it appears that you are soliciting proxies with respect to one
proposal and you have defined it in the first paragraph as the
"Proposal," please revise to remove any implication that there is
more than one proposal for which a proxy is being solicited.

9. On a supplemental basis, please confirm that you will file, on
the
date of first use, any written communications that may be
reasonably
viewed as soliciting material.  See Rule 14a-12.  All written
materials, press releases and any other written communications by
the
registrant should be filed verbatim immediately in accordance with
Rule 14a-12(b) as definitive additional materials.  In this
regard,
please note that your subsequent filings will not and cannot cure
the
deficiency with respect to delinquency and the failure to include
the
information required by Rule 14a-12(a)(1).  In addition, any
future
written communications should comply fully with the disclosure and
filing requirements of Rule 14a-12.

Cover page

10. Your statement in the second paragraph "that only the
preferred
holders can vote" is unclear, given that the notice given by Hecla
was actually made to common and preferred stockholders.  We
suggest
that you remove this clause.

11. You state that the proxy statement and proxy card will be sent
in
"definite" form.  Please revise to use the word "definitive,"
rather
than "definite."

12. We note your assertion that the election of your board
nominees
will "revitalize the Company and enhance preferred B shares."
Clarify the meaning of this statement and how it will be executed.
If you have no specific plans in mind, please indicate this.
Please
also indicate that there is no assurance that, if elected, you
will
be able to "revitalize the company and enhance preferred B
shares."

Reasons not to Re-elect the Company`s Board of Director`s proposed
slate

	Lack of Ownership of Hecla Preferred B

13. We note your statement that begins "Management`s nominee
directors...."  Please revise to clarify that Hecla`s Board of
Directors, rather than its management, is the entity responsible
for
the nomination of directors.

Reasons to Elect "preferredholders" to the Board of Directors
	1. "Preferredholders" Financial Interest

14. Please elaborate upon why you believe that your nominee`s
ownership of preferred shares is a reason to elect
"preferredholders."  Also, we note that the "preferredholders"
also
hold shares of common stock.  Why couldn`t the same allegation you
have made with respect to the board`s nominees - that they have a
financial incentive to favor the common shareholders - be made of
you?

15. Advise us what consideration has been given as to whether you
and
Mr. Miller have formed a "group" under Rule 13d-5(b)(1).  We note,
for example, that you and Mr. Miller collectively appear to own in
excess of 5% of the outstanding shares of preferred stock and
appear
to "have agreed to act together" for purposes of voting your
securities.  We may have further comment.

16. Please confirm on a supplemental basis that you have
identified
all participants in your solicitation or revise to provide all
information required by Items 4(b) and 5(b) of Schedule 14A.  In
this
regard, advise us why Charles E. Miller and Mr. David S. Miller`s
wife and daughter are not otherwise participants in the
solicitation.
Refer to Instruction 3 to Item 4 of Schedule 14A.

	2. Education and Financial Background

17. Confirm to us that you have provided all other information
about
the nominees required by Item 7(a), (b) and (c) of Schedule 14A.
If
not, then revise your proxy statement to include all required
information with respect to your nominees.  For example, please
revise the biographical information concerning your nominees to
disclose the dates of employment or service in each of the
positions
listed for a minimum of five years.  See Item 401(e) of Regulation
S-
K.

18. Please revise to indicate whether the nominees have consented
to
being named in the proxy statement and whether they have agreed to
serve if elected.  Refer to Rule 14a-4(d).  If any person has not
consented, then that person is not a bona fide nominee and you may
not name them in your materials pursuant to Rule 14a-4(d).

19. You state that "[f]or 32 years [Mr. David Miller] has been in
the
financial industry."  Disclose your definition of the "financial
industry."

20. Provide a description of the type of business conducted by
General Securities.

21. You mention that "Both Mr. David Miller and Dr. Thomas Miller
have experience in running a company...."  Describe what is meant
by
"running a company" and the extent of their experience.

	3. Will be Independent Directors
22. We note your reference in the header to "independent"
directors.
Clarify what you mean by your reference to "independent."  Is this
your definition or is this the definition as applied by the
listing
standards of the NYSE?  If this constitutes your definition,
briefly
define it for readers.

Solicitation of Proxies

23. We note that proxies may be solicited by "mail, facsimile,
telephone, telegraph, in person and by advertisements."  We remind
you to file, on the date of first use, all written soliciting
materials, including any scripts to be used in soliciting proxies
over the telephone, under the cover of Schedule 14A.  Refer to
Rule
14a-6(b) and (c).  Please confirm your understanding on a
supplemental basis.  Also confirm, if true, that proxies will not
be
solicited via the Internet, such as Internet chat rooms or
postings
on web sites.

24. Please clarify from whom you may seek reimbursement for
expenses.
See Item 4(b)(5) of Schedule 14A.

Other Matters and Additional Information

25. You state that "the `preferredholders` will bring before the
Annual Meeting such proposals as they believe to be appropriate."
On
a supplemental basis, please confirm that you will comply with
Hecla`s bylaws and the proxy rules by, for example, giving the
preferred shareholders adequate notice.  Further, you indicate
that
you will use discretionary authority to vote upon such matters.
Please note that you may not use discretionary authority conferred
with these proxies to vote upon matters not known to you at the
time
of this solicitation but which come to your attention a reasonable
time before the meeting.  See Rule 14a-4(c).  Please confirm your
understanding.

Company`s Proxy Materials
26. We note your reference to Hecla`s proxy materials as filed
with
us in lieu of presenting the information required to be included
in
your proxy statement.  Consider whether it might be more helpful
to
readers to make specific references to the sections of the
materials
that you are directing them to read.  You may omit such required
information in reliance upon Rule 14a-5(c) only to the extent the
information appears in "other proxy soliciting material which has
been furnished."  It does not appear appropriate for you to rely
on
Rule 14a-5 since the company`s proxy statement has not yet been
furnished.  Therefore, please confirm your understanding that you
may
not disseminate your materials until the company has mailed
definitive proxy solicitation materials.

Alternatively, if you plan to solicit proxies in advance of the
company mailing their definitive proxy materials, please revise to
include all information required by the proxy rules and Schedule
14A,
including the number of shares outstanding, the current number of
shareholders of Hecla`s common stock and any other information
required in your proxy that can be obtained from Hecla`s most
recent
filings under the Exhange Act.  See, for example, the information
required by Item 6 and 21 of Schedule 14A.  To the extent any of
that
information is updated in a proxy filing made by the company, you
may
revise your materials to update accordingly.

Form of Proxy
27. Revise the form of proxy to state in bold-face type that the
proxy is being solicited on behalf of the participants and not on
behalf of the Company`s board of directors.  Please make a similar
change to the cover page.  Refer to Rule 14a-4(a).

28. Please revise the proxy card to place the instruction
indicating
how to withhold authority to vote for any nominee in boldface type
as
required by Rule 14a-4.  Please also ensure that you have clearly
identified the means by which preferred shareholders may withhold
authority to vote for each nominee; the manner in which this
appears
to be set forth on the card you filed on EDGAR is confusing to
read.

Closing comments

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the filing persons are in possession
of
all facts relating to the disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the filing persons acknowledging
that:

* the filing persons are responsible for the adequacy and accuracy
of
the disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the filing persons 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filings.

Closing Information

      Please respond to these comments by filing a revised
preliminary proxy statement and continue to comply with our
comments
when disseminating information in the future.  When you respond,
please furnish a cover letter that keys your responses to our
comments.  If you believe that compliance with our comments is not
appropriate, please provide the basis for your view in your
response
letter, which you should file electronically on EDGAR under the
tag
"CORRESP."  Please also note the location of any material changes
made in the materials for reasons other than in response to
specific
staff comments.  Also, note the requirements of Rule 14a-6(h) of
Regulation 14A and Rule 310 of Regulation S-T.

*******

      Direct any questions to me at (202) 551-3264.  You may also
contact me via facsimile at (202) 772-9203.  In my absence, you
may
also contact Jason E. Wynn at (202) 824-5665.  Please send all
correspondence to us at the following ZIP code:  20549-0303.

								Sincerely,

								Mara L. Ransom
								Office of Mergers
      and Acquisitions

cc:  	J. Wynn
	R. Schwall

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David S. Miller
May 5, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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