SecProbe.io

September 20, 2011
 Via Mail

Edward D. Ford Chief Financial Officer North American Nickel Inc. 301 - 260 West Esplanade North Vancouver, BC V7M 3G7
Re: North American Nickel Inc.
 Form 20-F for Fiscal Year Ended
December 31, 2010 Filed April 20, 2011 File No. 001-14740

Dear Mr. Ford:
We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  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 comments apply 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.  Engineering Comments

Form 20-F for Fiscal Year Ended December 31, 2010
 General

 1. We note your web site contains disclosure about adjacent or other properties on which
your company has no right to explore or mine, it would be helpful for you to include the following cautionary language along with such information:

“This web site contains information about ad jacent properties on which we have no right
to explore or mine.  We advise U.S. invest ors that the SEC’s mining guidelines strictly
prohibit information of this type in document s filed with the SEC.  U.S. investors are

Edward D. Ford
North American Nickel Inc. September 20, 2011 Page 2

 cautioned that mineral deposits on adjacent pr operties are not indicative of mineral
deposits on our properties.”

Please indicate the loca tion of this disclaimer in your response.
 2. We note that you have quantified minerali zation on your website and in some press
releases.  If you continue to disclose measur es other than those recognized by the SEC,
on your website, in press releases or in your filings with the SEC, please accompany such
disclosure with the following cautionary language:

Cautionary Note to U.S. Investors -The  United States Securities and Exchange
Commission permits U.S. mining companies,  in their filings with the SEC, to
disclose only those mineral deposits that a company can economically and legally extract or produce.  We use certain terms on this website (or press release), such
as “measured,” “indicated,” and “inferred”  “resources,” which the SEC guidelines
generally prohibit U.S. registered compan ies from including in their filings with
the SEC.  U.S. Investors ar e urged to consider closely the disclosure in our Form
20-F which may be secured from us, or accessed from the SEC website at http://www.sec.gov/edgar.shtml
.

Please indicate the location of this cautionary lan guage in your response.

Sudbury Nickel Properties, page 8
 3. We note your disclosure in this section and elsewhere in your filing referring to mines
and other mineral properties that exist in the proximity of your property.  Such disclosure
may cause investors to infer that your pr operty also has commercial mineralization,
because of its proximity to these mines a nd properties.  Please describe only geology,
history, or exploration results that are directly related to the properties that your company
has the right to explore or mine.  Acco rdingly, it appears that you should remove
information about any mines, prospects, adjacent or analogous properties, deposits, occurrences, or exploration activities by other companies operating in or near your
properties and instead focus the disclosu re solely on your company’s property.
 4. Please disclose the following information for each of your properties:

 The nature your ownership or  interest in the property.

 A description of all interest s in your properties, includi ng the terms of all underlying
agreements and royalties.

 Describe the process by which mineral right s are acquired at this location and the
basis and duration of your mineral right s, surface rights, mining claims or
concessions.

Edward D. Ford
North American Nickel Inc. September 20, 2011 Page 3

  An indication of the type of claim or conce ssion such as placer or  lode, exploration or
exploitation, whether the mini ng claims are State or Fede ral mining claims, patented
or unpatented claims, mining leas es, or mining concessions.

 Please include certain identif ying information, such as the property names, claim
numbers, grant numbers, mining concession na me or number, and dates of recording
and expiration that is sufficient to enable the claims to be distinguished from other
claims that may exist in th e area or your properties.

 The conditions that must be met to retain your claims or leases, including
quantification and timing of all necessary  payments, annual maintenance fees, and
disclose who is responsible for paying these fees.

 The area of your claims, either  in hectares or in acres.

Please ensure that you fully discuss the mate rial terms of the land or mineral rights
securing agreements, as required under paragraph (b)(2) of Industry Guide 7.
 5. Please disclose the information required under paragraph (b) of Industry Guide 7 for all
your material properties listed under this head ing.  For any properties  identified that are
not material, please include a statement to that  effect, clarifying your intentions.  For each
material property, include the following information:

 The location and means of access to your  property, including the modes of
transportation utilized to and from the property.

 Any conditions that must be met in order to  obtain or retain title to the property,
whether your have surface and/or mineral rights.

 A brief description of the rock formations  and mineralization of  existing or potential
economic significance on the property.

 A description of any work completed on the property and its  present condition.

 The details as to modernization and physic al condition of the pl ant and equipment,
including subsurface improvements and equipment.

 A description of equipment, infr astructure, and other facilities.

 The current state of expl oration of the property.

 The total costs incurred to date and all planned future costs.


 The source of power and water that can be utilized at the property.

Edward D. Ford
North American Nickel Inc. September 20, 2011 Page 4

  If applicable, provide a clear statement th at the property is without known reserves
and the proposed program is exploratory in nature.

You may refer to Industry Guide 7, paragraphs  (b) (1) through (5), for specific guidance
pertaining to the foregoin g, available on our website at the following address:
www.sec.gov/about/forms/industryguides.pdf
.
 6. Please insert a small-scale map showing the location and access to each material
property, as required by Instruct ion 1(a) to Item 4.D of Form 20-F.  Please note the
EDGAR program now accepts Adobe PDF files and digital maps, so please include these
maps in any amendments that are uploaded to  EDGAR.  It is relatively easy to include
automatic links at the appropriate locations within the document to GIF or JPEG files,
which will allow figures and diagrams to appear in the right location when the document is viewed on the Internet.  For more info rmation, please consult the EDGAR manual, and
if additional assistance is required, please call Filer Support at (202) 551-3600 for Post-
Acceptance Filing Issues or (202) 551-8900 for Pre-Acceptance Filing Issues.  We believe the guidance in Instruction 1(a) to It em 4.D of Form 20-F would generally require
maps and drawings to comply  with the following features:

 A legend or explanation showing, by means of  pattern or symbol, every pattern or
symbol used on the map or drawing.

 A graphical bar scale should be included.  A dditional representations of scale such as
"one inch equals one mile" may be utilized provided the original scale of the map has not been altered.

 A north arrow.

 An index map showing where the property is situated in relations hip to the state or
province, etc., in which it was located.

 A title of the map or drawing, and the date on which it was drawn.

 In the event interpretive data is submitted in conjunction wi th any map, the identity of
the geologist or engineer that prepared such data.

Any drawing should be simple enough or of suff iciently large scale to clearly show all
features on the drawing.

Edward D. Ford
North American Nickel Inc. September 20, 2011 Page 5

 Woods Creek, page 9

 7. We note you disclose assay results up to 1.09%  Nickel.  When reporting the results of
sampling and chemical analyses, please revise  your disclosure to address each of the
following regarding mineralization of existi ng or potential economi c significance on your
property:

 Disclose only weighted-average sample an alyses associated with a measured length
or a substantial volume.

 Eliminate all analyses from “grab” or “dump” samples, unless the sample is of a
substantial and disclosed weight.

 Eliminate all disclosure of th e highest or best values/grade s of sample sets.  Present a
balanced disclosure of the drill and sampling results

 Eliminate grades disclosed as “up to” or “as high as” or “ranging from.”

 Eliminate statements containing gr ade and/or sample-width ranges.

 Aggregated sample values from related locations should be aggregated based on a
weighted average of lengths of the samples.

 Generally, use tables to improve read ability of sample and drilling data.

 Soil samples may be disclosed as a weighted average value over an area.

 Refrain from reporting si ngle soil sample values.

 Convert all ppb quantities to ppm  quantities for disclosure.

 Avoid optimistic descriptive adjectives such as high-grade or ore-grade.

Please revise your disclosures to comply w ith this guidance.  Please note the TSX
Venture Exchange Corporate Finance Manua l – Appendix 3F also addresses many of
these items.

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.

Edward D. Ford
North American Nickel Inc. September 20, 2011 Page 6

 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d 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.

You may contact George K.  Schuler, Mine Engineer at (202) 551-3718 if you have
questions regarding the engineer ing comments and related matters.  Please contact me at (202)
551-3311 with any other questions.
Sincerely,
   /s/ Ethan Horowitz
Ethan Horowitz Branch Chief