SecProbe.io

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								August 22, 2005

Mr. Jamie C. Sokalsky
Chief Financial Officer
Barrick Gold Corporation
BCE Place
Canada Trust Tower
161 Bay Street, Suite 3700
P.O. Box 212
Toronto, Canada M5J 2S1

	Re:	Barrick Gold Corporation
		Form 40-F for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
      File No. 001-09059

Dear Mr. Sokalsky:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 40-F for the Fiscal Year Ended December 31, 2004

Narrative Description of the Business, page 15

Principal Regions, page 23

1. We note that your presentation of "Total cash costs - per US
GAAP," under this heading and throughout your filing, equals "cost
of
sales and other operating expenses less accretion expense and
reclamation costs at non-operating mines."  Please note that your
cost of sales line item, which excludes amortization of property,
plant and equipment, does not follow the full absorption costing
principle since the measure does not include all costs and
expenses
associated directly with or allocated to your products sold.  We
believe cost of sales should include inventoriable costs of assets
incident to or necessary for production or manufacturing,
including
applicable depreciation, depletion and amortization.  Please
revise
your presentation accordingly or explain to us why it is
appropriate
to disclose this measure in your filing.  If you determine it is
appropriate to disclose this measure, please revise your caption
to
refer to this measure in a manner that more clearly explains how
it
is calculated and include all disclosures required by Question 8
of
the Division of Corporation Finance`s June 13, 2003 Frequently
Asked
Questions Regarding the Use of Non-GAAP Financial Measures,
located
at: http://www.sec.gov/divisions/corpfin/faqs/nongaapfaq.htm.  We
note a similar measure disclosed on page 93 entitled "Total cash
production costs - per US GAAP."

Note 16. Financial Instruments, page 97

Accounting policy for derivatives, page 100

2. We note that you have elected to designate your gold and silver
sales contracts as "normal sales contracts" under paragraph 10(b)
of
FAS 133.  We further note under your disclosure of off balance
sheet
arrangements on page 53 in your MD&A that you have had gold sales
contracts in the past with bullion-banking counterparties.  With
respect to your gold and silver sales, please provide an analysis
of
the different type of contracts that you presently have,
indicating
the (i) counterparties involved and (ii) the type of product that
you
physically deliver from your mines to each of the counterparties
involved.  Please specify whether or not the counterparty that
receives physical delivery of an unrefined product from your mine
is
the same counterparty that receives physical delivery of a refined
product from your mine.

Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure 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
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 filing.

      You may contact Jennifer Goeken at (202) 551-3721 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3683 with any other
questions.

								Sincerely,

								Jill S. Davis
								Branch Chief
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Mr. Jamie C. Sokalsky
Barrick Gold Corporation
August 22, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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