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Hecla Mining Correspondence dated May 2, 2005

     BELL,
 BOYD
 & LLOYD
 LLC

70 West Madison Street,
Suite 3100  •  Chicago,  Illinois  60602-4207
  312.372.1121  •  Fax
312.827.8000

John H. Bitner
312.807.4306

jbitner@bellboyd.com
 Direct Fax: 312.827.8048

Via E-mail and EDGAR

May
2, 2005

Mr. Roger H. Schwall,
Assistant  Director, Office of Natural Resources and Food

Mr. Brian V. Breheny, Chief, Office of Mergers and Acquisitions

Ms. Mara Ransom, Office of Mergers and Acquisitions

Division of Corporation Finance
 Securities and Exchange Commission

450 Fifth Street, N.W.
Washington, D.C. 20549

Hecla Mining Company
Commission File No.
1-8491

Dear Messrs. Schwall and Breheny and
Ms. Ransom:

        As
counsel for Hecla Mining Company, we have previously called to the attention of the Staff
the apparent violation of the Commission’s Proxy Rules 14a-3 and 14a-6 by David
Miller and Thomas Miller and their affiliates in connection with their dissemination of
unfiled proxy solicitation materials to holders of Hecla’s Class B Preferred Stock
related to the election of two preferred directors at Hecla’s annual meeting of
stockholders scheduled for May 6, 2005. In that connection, we furnished to the Staff
a copy of a purported proxy statement and card circulated at the Millers’ request by
ADP beginning on April 18, 2005.

        We
learned on April 29, 2005 that the Millers made a filing of preliminary proxy material,
and would like to call the Staff’s attention to the following deficiencies in that
filing (nearly all of which occurred as well in the materials which were furnished holders
of Hecla Preferred Stock without the required filings).

             1.
          The proxy statement is headed “HECLA MINING COMPANY,” which is
          misleading because it conveys the impression that the materials are being
          circulated by Hecla. The same is true of the proxy card, which is similarly
          headed, followed by Hecla’s address. At the least, the Hecla name should be
          moved to the end of the third line of text and follow the phrase “BOARD OF
          DIRECTORS [OF],” and the name moved in the proxy card to follow
          “Annual Meeting of Shareholders [of]” and the address deleted.

             2.
          In the first paragraph on page 1 (references to pages in these comments are to
          the pages in the order, unnumbered, in which they appear in the EDGAR filing) of
          the

c   h   i   c   a
 g   o      •      w   a   s   h
 i   n   g   t   o   n

     Mr. Roger H. Schwall
 Mr. Brian V. Breheny

 Ms. Mara Ransom
May 2, 2005
Page 2

materials, the Millers identify
themselves with the defined term “preferredholders,” which is misleading because
it conveys the impression that they represent all or some group of the holders of
Hecla’s preferred stock other than themselves and are “preferred” to the
Board’s nominees. It is confusing to refer to the holders of the Company’s
preferred stock as a group. We believe this defined term is a deliberate
mischaracterization, and suggest that the Millers could identify themselves much more
appropriately as the “Millers.”

             3.
          In the same paragraph of text, note that the election of the two Millers is
          defined as their “Proposal.” In several other places in their
          materials, the dissidents refer to a “proposal” or
          “proposals.” See, e.g., our comment 14 below. We suggest the
          materials be revised to refer to an “election” or “voting for
          directors” rather than variously as Proposal, proposal or proposals.

             4.
          In the second paragraph of text, the second line, the reference to “that
          only preferred holders can vote” is confusing, at best.

             5.
          The last sentence of the second paragraph is an example of the use of the term
          “shareholders,” prevalent throughout the proxy materials, without
          specifying that it means holders of preferred stock and not holders of common
          stock. In several places in their proxy statement, the dissidents use the word
          “shares,” without specifying whether the reference is to common or
          preferred shares. See, e.g., the dissidents’ Point 1 under
          “Reasons…” on page 2 of their proxy statement and our comment 16
          below.

             6.
          The use of the word “definite” in the last sentence of the second
          paragraph on page 1 is incorrect, and another example of imprecision, and the
          April 12, 2005 date is incorrect (and curious).

             7.
          In the second to last full paragraph on page 1, the references to
          “revitalize” and “enhance” are misleading. Nowhere do the
          dissidents explain why Hecla needs “revitalizing” nor how they intend
          to do it, nor do they explain how they will “enhance” the preferred
          shares.

             8.
          In the first full paragraph on page 2 of their materials, the dissidents
          disclaim having any arrangement or understanding with any of the current members
          of the Board of Directors, “or any of the other
          nominees. . .,” apparently not realizing that there are not
          any Board nominees who are not currently directors.

        The
direct implication of this paragraph is that the two Millers have no arrangement between
themselves, which seems highly unlikely. Also, two paragraphs later they refer to Charles
Miller, a third brother. Is he a participant? Is there any arrangement with him?

             9.
          In the first paragraph numbered 1 on page 2, the dissidents refer to
          “management’s nominee directors,” when the nominees to which they
          refer were selected by the Board of Directors, which is the entity soliciting
          proxies in opposition to the Millers.

     Mr. Roger H. Schwall
 Mr. Brian V. Breheny

 Ms. Mara Ransom
May 2, 2005
Page 3

             10.
          The dissidents state in the first paragraph numbered 1 on page 2 that the
          nominees they oppose own more Hecla common stock than preferred stock, thus
          giving them a financial incentive to favor common shareholders at the expense of
          preferred shareholders, without stating what that financial incentive might be
          or how the Board’s nominees might act on any such incentive and without
          acknowledging that the Millers also own more common shares than preferred
          shares. If the suggestion is that not paying dividends on preferred stock favors
          holders of common stock, that ignores the fact that no cash dividends may be
          paid on Hecla’s common stock while preferred dividends are in arrears.

             11.
          Beginning in the second paragraph numbered 1 on page 2, the Millers provide
          certain information with respect to their preferred and common shareholdings of
          Hecla, but not in the tabular form, with percentages, required by the Proxy
          Rules, and without giving the required information on any transactions by them
          or their affiliates in common or preferred shares in the preceding two years,
          even though prior statements of the Millers suggest such transactions have
          occurred. They also neglect to give their ages or principal business occupations
          in the preceding five years, including the principal businesses in which their
          employers were engaged, their business addresses, and any other information
          required by Item 5(b) of Schedule 14A. In addition, the references to their
          having “run… a company” and a “working knowledge of
          financial statements” is misleading because it is not defined.

        We
note that David Miller identifies himself as having started General Securities, located in
Kansas City, with 18 registered “reps.” We have found a General Securities Corp.
in Kansas City on the NASD’s website, identifying David Miller as a principal. We
find it particularly egregious that an SEC-and-NASD registered principal of a securities
brokerage firm would so blatantly ignore the federal securities laws.

        We
further note several NASD disciplinary proceedings and findings against David Miller and
his firm reported by the NASD on its website.

        We
also again call to the Staff’s attention the failure of David and Thomas Miller, who
disclose in their materials that they are acting together as a group for the purpose of
voting more than 5% of the outstanding preferred shares of Hecla, which is a class of
equity securities registered under the Securities Exchange Act of 1934, to file a Schedule
13D. See Rule 13d-5(b)(1). By their numbers, the two Millers own a total of 9,200, or 5.8%
of the 157,810 shares of Hecla preferred stock outstanding at March 10, 2005. If the
holders of the other Miller family members are added, the percentage increases to 8.1.

        The
principal shareholder information should be included in tabular form in the
dissidents’ material.

             12.
          In point 3 beginning at the bottom of page 2 of their materials, the Millers
          state that they have not had and will not have any interest in any transactions
          in which Hecla is or will be a party, without indicating that if they are
          successful in causing Hecla to pay dividends

     Mr. Roger H. Schwall
 Mr. Brian V. Breheny
 Ms. Mara Ransom

May 2, 2005
Page 4

in
arrears,  they will receive significant amounts.  Further,  they do not disclose
the  directors’  fees and other compensation to which they will be entitled
if elected to Hecla’s Board.

             13.
          By indicating in “Reasons to Elect…” on page 2, point 3,
          that they will be independent, the dissidents misleadingly imply that the other
          nominees do not meet independence standards which are currently applicable. As
          noted on page 10 of Hecla’s March 29, 205 proxy statement,
          Hecla’s Board affirmatively determined Messrs. Taylor and Christensen to be
          independent and as noted on page 11, Mr. Christensen has been appointed by the
          independent members of Hecla’s Board to preside over meetings of the
          independent directors.

             14.
          In the first full paragraph on page 3, and in the third full paragraph, the
          dissidents refer to “proposals,” and the “Proposal,” adding
          further to the confusion noted in our comment 3 above. The reference in the
          first full paragraph on page 3 to “immediately” executing a proxy
          seems a little overdone.

             15.
          The dissidents fail to disclose what happens with respect to broker-nonvotes,
          and neglect to indicate the color of their proxy. They do refer to the
          Board’s proxy as “white” in the second full paragraph on page 3
          of their materials. We are informed by ADP that the dissidents’ proxy
          mailed on April 18, 2005 was also white, which will serve to confuse holders of
          preferred shares. We suggest the dissidents follow custom and use blue cards,
          and refer to the color in the proxy statement.

             16.
          The reference in the last sentence of the second full paragraph on page 3 to
          “all shares” is another example of the dissidents’ failure to
          distinguish between common and preferred shares of Hecla.

             17.
          In the last sentence of the third full paragraph on page 3, the dissidents again
          refer to the “Proposal,” without indicating that shareholders may vote
          for one or more directors and/or direct that authority be withheld for one or
          more directors. The word “PROPOSAL” is similarly mis-used in
          the third line of the capitalized legend below that paragraph.

             18.
          Under “GENERAL-Solicitation of Proxies” on page 3, the
          dissidents neglect to state from whom they might seek reimbursement for
          expenses.

             19.
          In the first full paragraph on page 4, the dissidents state that they
          “will” bring before the annual meeting such “proposals” as
          they deem appropriate, without specifying what those may be nor indicating that
          they have not complied with Hecla’s by-laws with respect to required
          notices for such proposals to be properly presented at the meeting (nor given
          holders of preferred shares the opportunity to vote on whatever they might
          present).

     Mr. Roger H. Schwall
 Mr. Brian V. Breheny
 Ms. Mara Ransom

May 2, 2005
Page 5

             20.
          In the capitalized legend on page 4 of the materials, the dissidents refer to
          voting for the election of their nominees “AND FOR THE PROPOSAL,”
          another example of their confusion of election of directors with proposals.

             21.
          The same confusion exists in the proxy card, which mis-refers in the first
          paragraph of text to the “proposals set forth below.” That same card
          should not have “HECLA MINING COMPANY,” with its address, at the top,
          because it misleadingly implies that the proxy is being solicited by Hecla.
          Again, we suggest as a minimum moving Hecla’s name after “Annual
          Meeting of Shareholders” and deleting Hecla’s address.

             22.
          We believe the attempted incorporation by reference to Hecla’s proxy
          materials on page 4 is inadequate, and that Proxy Rule 14a-5(c) contemplates a
          “clear reference” to each item in Hecla’s proxy statement to
          which the dissidents believe they are referring.

             23.
          We assume the dissidents’ materials will be appropriately revised to
          reflect the adjournment of the portion of the Hecla annual meeting of
          shareholders, as to which Hecla filed an announcement on April 28, 2005.

     *      *      *

        If
any member of the Staff would like to discuss further any of these deficiencies, or other
possible deficiencies depending on the applicability of certain items (e.g., legal
proceedings), please feel free to get in touch with the undersigned at 312.807.4306, or
Don Bingle of this office, at 312.807.4248.

     Very truly yours,

BELL,
 BOYD &
 LLOYD
 LLC

By
      John H. Bitner

JHB:azs

Copy to Michael B. White,
Esq