SecProbe.io

CORRESP
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filename1.htm

Unassociated Document

April 28,
2005

Mr. Roger
Baer

Mining
Engineer

Division
of Corporate Finance, Stop 0405

SECURITIES
AND EXCHANGE COMMISSION

450
5th St.,
NW

Washington,
DC 20549-0405

Re:
Capital
Gold Corporation Registration Statement on Form
SB-2; SEC File No. 333-123216

Dear Mr.
Baer:

Pursuant
to comment No. 5 (Engineering Comments) in the April 8, 2005 comment letter from
the Securities and Exchange Commission to Capital Gold Corporation (the
“Company”), I am delivering, on a supplemental basis, the August 8, 2003 El
Chanate Gold Mine Feasibility Study prepared by M3 Engineering of Tucson,
Arizona (the “Feasibility Study”). As we discussed, the Feasibility Study is
contained on the enclosed CD-ROM.

There are
three volumes to the Feasibility Study included on the CD-ROM as
follows:

    Volume I: Executive Summary

    Volume II (Appendices): Geology and
      Mining

    Volume II: Geology and Mining

    Volume III: Process, Infrastructure and
      Financials

 In
addition to the CD-ROM, I am enclosing four folded table size maps and a printed
version of the Executive Summary. The enclosed maps are:

      General
      location map scale 1:30,000

    Topography & property map scale 1:50,000

    Drill hole location map 1:2,500 scale; and

    Drill hole gold grade map scale 1:2,500

To assist
you in your review of the Feasibility Study, please note that information with
regard to the bullet points in comment No. 5 can be found on the following pages
of the Feasibility Study:

     Comment

    Volume;Chapter;Page
      Nos.

      Property
      and geologic maps

      Vol
      I; pg 10; also see maps folded separately

      Description
      of your sampling and assaying procedures

      Vol
      II; Ch 3; pg 16

      Drill-hole
      maps showing drill intercepts

      Vol
      II; Figures 3-2, 3-20, 3-21, 3-22,and see folded map.

      Representative
      geologic cross-sections and drill logs

      Vol
      II; Figures 3-25, 3-26, 3-27, and see drill logs on
  CD-ROM

      Description
      and examples of your cut-off calculation procedures

      Vol
      II; Ch 4; pg 3

      Cutoffs
      used for each category of reserve and any resources

      Vol
      II; Ch 4; pgs 2 & 3

      Justifications
      for the drill hole spacings used at various classification
      levels

      Vol
      II; Ch 3; pgs 14, 50-52

      A
      detailed description of our procedures for estimating “reserves” and
      “resources,” if developed

      Vol
      II; Ch 3; pgs 4 -72

      Copies
      of pertinent engineering and geological reports, and feasibility studies
      or mine plans (including cashflow analyses) concerning your property that
      are needed to establish the existence of reserves as defined in Industry
      Guide 7

      Vol
      II; Ch 4; pgs 1-32

      &
      Vol
      III; Ch 15; pgs 1-7

Independent
Mining Consultants in Tucson, Arizona determined the reserves and resources and
you should feel free to contact:

      Mr.
      Herb Welhener

    Vice President and Principal Mining Engineer

    Independent Mining Consultants,
  Inc.

    2700 E. Executive Drive, Suite
  140

    Tucson, AZ 85706

    Phone: (520) 294-9864

    Fax: (520)
294-9865

If you
have any questions or need additional information, please do not hesitate to
call me at (303) 526-5100.

Very
truly yours,

    CAPITAL GOLD
      CORPORATION

    /s/ Roger A.
      Newell

      Roger A. Newell, Ph.D.

    Vice-President of
      Development

      Enclosures