SecProbe.io

M a r c h  4 ,  2 0 1 1

Mr. Carl R. Jonsson
Secretary and Director, 1710 -1177 West Hastings Street Vancouver, B.C., Canada
V6 E21.

 Re: Caledonia Mining Corporation
  Form 20-F/A for the Fiscal Year ended December 31, 2009
Filed October 1, 2010 Response letter dated March 1, 2011
  File No. 000-13345

Dear Mr. Jonnson,
We have reviewed your response letter and have the following comment.  We ask that
you provide us with additional 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 comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Form 20-F/A for the Fiscal Year ended December 31, 2009

Information on the Company, page 10

Business Overview, page 11

Reserves – Blanket Mine

1. We have read the response material you provided on March 1, 2011, including the
disclosure you propose to include in an amen dment to your annual re port, clarifying that
you have not prepared a current mineral rese rve estimate for any date subsequent to
December 31, 2006.  You also indicate that you believe the effect of using the straight
line method rather than the units-of-producti on method of calculating DD&A for 2009 is
not material.

Mr. Carl R. Jonsson Caledonia Mining Corporation
March 4, 2011 Page 2

As previously explained, we  believe that you need to include a current estimate of
mineral reserves in your f iling to comply with your re porting obligations under the
Securities Exchange Act.  We understand fr om our phone conference on February 28,
2011 that investors are not able to fully rely on the estimates that you will present in the
roll-forward schedule due to your  failure to calculate the effects of changes in factors
utilized to compute your origin al estimate.  If the disclo sure and amendment you propose
are intended as interim measures until you complete your reserve study then please
expand that disclosure to clarify – it should be clear when you expect to amend the filing
again to include your estimate of  reserves as of December 31, 2009.

As for your analysis of the accounting implica tions, we believe that you need to address
all years presented in the filing and any carry-over differences from earlier years.  In the
materials you submitted you describe your co mputation of the accounting effects under
the units-of-production method as being “bas ed on planned production tonnes.”  As the
meaning of this statement is unclear, we would like you to explain how the factors
utilized in your computation compare to ac tual production in each period; and since you
do not have a current estimate of the reserv e base for any of the years presented, we
would like you to further explain the extent  of support for your view on materiality.

It appears that any in terim disclosure would need to a ddress the uncertain ties inherent in
your accounting for DD&A – that your accounti ng results may differ from those that
would have been reported under the units-of- production method – and advise readers that
you will evaluate the accounting and determine whether there were material differences
once you have an accurate estimat es of your mineral reserves.
 Closing

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 and 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.

Mr. Carl R. Jonsson Caledonia Mining Corporation March 4, 2011 Page 3

You may contact George K. Schuler Mining Engineer, at (202) 551-3718 if you have
questions regarding the comments on your property disclosures.  Please contact me at (202) 551-
3686 with any other questions.
         S i n c e r e l y ,
Karl Hiller Branch Chief