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CORRESP
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SEC Correspondence Letter

P.O. Box 49330 Bentall Station

Suite 1600 – 1055 Dunsmuir Street

Vancouver, British Columbia, Canada, V7X 1P1

April 8, 2005

VIA COURIER AND FACSIMILE: (202) 942-9528

Mr. H. Roger Schwall

Assistant Director, Division of Corporation Finance

United States Securities and Exchange Commission

Washington, D.C.

20549-0405

    Re:
    Placer Dome Inc. (“Placer Dome”)

Form 40-F for the year ended December 31, 2004, Filed March 4, 2005

File No. 001-09662

Dear Mr. Schwall:

In response to your letter of March 29, 2005 related to our Form 40-F for the year ended
December 31, 2004 (the “40-F”) and to the Financial Statements — Note 20(d),
Supplementary Information (Reconciliation of net earnings between the U.S. and Canadian
basis) contained therein, we confirm that the estimates for the reserves for the South
Deep mine meet the standards of Industry Guide 7.

Placer Dome’s 2004 reserve estimates for the South Deep mine are based on work carried
out in July 2004 by Steffen, Robertson and Kirsten (South Africa) (Pty) Ltd. (“SRK”), an
independent international engineering firm experienced in this area. SRK acted as an
expert for the reserve determination at the South Deep mine in July 2004 and was named as
the Qualified Person for that disclosure, as required pursuant to Canadian securities
regulation NI 43-101, in our press release relating to South Deep’s reserves and
resources filed under Form 6-K on August 5, 2004, a copy of which is enclosed herewith.

Placer Dome’s 2004 year end disclosure of the South Deep reserves represents a reserve
estimate based on the depletion of the July 2004 estimate to account for the mine
production during the latter half of the year.

With respect to your closing comments, we acknowledge that:

    •
    Placer Dome is responsible for the adequacy and accuracy of the disclosure in the 40-F filing;

TEL (604) 682-7082          FAX (604) 682-7092

WEB www.placerdome.com

A member of the Placer Dome Group

CONTINUED Page 2

    •
    Staff comments or changes to disclosure in response to staff comments do
not foreclose the United States Securities and Exchange Commission (the
“Commission”) from taking any action with respect to the 40-F filing; and

    •
    Placer Dome 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.

Your letter also requested a contact for technical questions about our reserves. We
advise that Mr. Alfred Hills, PEng., Vice-President, Evaluations (604-661-1923) is the
appropriate contact for these matters.

Should you have any further questions or comments related the foregoing or other matters
set out in Placer Dome’s 40-F, please do not hesitate to contact the undersigned or Mr.
Bruce Nicol, Vice-President and Controller (604-661-3728).

Yours truly,

PLACER DOME INC.

Rex J. McLennan

Executive Vice-President and CFO

Enclosure

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 6-K

Report of Foreign Private Issuer

Pursuant to Rule 13a-16 or 15d-16 of

the Securities Exchange Act of 1934

For the month of August, 2004

PLACER DOME INC.

Suite 1600, 1055 Dunsmuir Street

P.O. Box 49330, Bentall Postal Station

Vancouver, British Columbia

Canada V7X 1P1

     Indicate by check mark whether the registrant files or will file annual reports
under cover Form 20-F or Form 40-F.

    Form 20-F     o

    Form 40-F     þ

     Indicate by check mark whether the registrant by furnishing the information
contained in this Form is also thereby furnishing the information to the Commission
pursuant to Rule 12g3-2(b) under the Securities Exchange Act of 1934.

    Yes     o

No     þ

FORM 51-102F3

Material Change Report

Item 1.     Name and Address of Company

                  PLACER DOME INC.

                  Suite 1600
– 1055 Dunsmuir Street

                  Vancouver, BC V7X 1P1

Item 2.     Date of Material Change

                  July 29, 2004

Item 3.     News Release

                  A news release was issued by Placer Dome Inc. through the facilities of Canada NewsWire
Limited (Canadian Disclosure Network), Vancouver and various other news dissemination facilities
and publications on July 29, 2004.

Item 4.     Summary of Material Change

                  Placer Dome Inc. announced updated mineral resource and mineral reserve estimates at the South
Deep mine in South Africa.

Item 5.     Full Description of Material Change

                  Placer Dome Inc. announced updated mineral resource and mineral reserve estimates at the South
Deep mine in South Africa. A qualified person employed by the Placer Dome Western Areas Joint
Venture (PDWAJV), which is 50% owned by Placer Dome, prepared the mineral resource estimate.
Steffen, Robertson and Kirsten (South Africa) (Pty) Ltd. (“SRK Consulting”) were retained by the
PDWAJV to review the mine’s mineral reserve estimation process and a representative of SRK
Consulting has acted as the Qualified Person for the updated mineral reserve estimate.

                  At June 30, 2004, Placer Dome’s share of proven and probable gold mineral reserves is
estimated at 27.9 million ounces. This estimate is largely unchanged from the proven and probable
gold mineral reserves reported at December 31, 2003. Placer Dome’s share of measured and indicated
gold mineral resources, based on a 5g/t cut-off, is estimated at 37.5 million ounces, inclusive of
mineral reserves. This is a reduction of approximately 22% from measured and indicated gold mineral
resources, inclusive of mineral reserves, at December 31, 2003. The updated estimates were prepared
using a gold price of $325 per ounce, an exchange rate of 8.75 rand per U.S. dollar and include a
cost for the South African government’s proposed royalty.

In completing its review, SRK Consulting has determined that additional geological modeling at
South Deep is advisable, and the mineral reserve estimate has been qualified accordingly. SRK
Consulting is of the view that additional geological modeling would improve the understanding of
the Phase 1 mine mineral resource estimate and thus reduce the risks associated with applying this
interpretation to the Phase 2 area. It would also improve the confidence in the various mining
methods selected for Phase 2 and associated production schedules.

                  Accordingly, the mine will continue work to improve the mineral resource and mineral reserve
estimation to address the qualifying issues raised by SRK Consulting. This is consistent with

the ongoing mineral resource estimation process of the mine and its strategy to optimize the
operation. Additional geological modeling, changes in economic assumptions and the long-term cost
structure of the mine may impact future mineral reserve and mineral resource estimates. It is
expected that this work will be completed for Placer Dome’s year-end 2005 disclosure.

                  The mine continues to complete its near-term mine plan taking into consideration the current
cost environment, the completion of the shaft system and the impacts of the newly enacted Mineral
and Petroleum Resources Development Act. It is expected that production rates over the next two
years will be similar to those of 2004.

    Proven mineral reserves

    Probable mineral reserves

    Total proven and probable mineral reserves

    Tonnes

    Grade

    Contained oz.

    Tonnes

    Grade

    Contained oz.

    Tonnes

    Grade

    Contained oz.

    Recovery

    (000s)

    (g/t)

    (000s)

    (000s)

    (g/t)

    (000s)

    (000s)

    (g/t )

    (000s)

    (%) (1)

                                  South Deep (50%)

    6,517

    9.5

    1,989

    104,683

    7.7

    25,919

    111,200

    7.8

    27,908

    97
    %

    Measured mineral resources

    Indicated mineral resources

    Total measured and indicated mineral resources

    Tonnes

    Grade

    Contained oz.

    Tonnes

    Grade

    Contained oz.

    Tonnes

    Grade

    Contained oz.

    (000s)

    (g/t)

    (000s)

    (000s)

    (g/t)

    (000s)

    (000s)

    (g/t )

    (000s)

                               South Deep (50%)

    8,403

    10.8

    2,925

    109,544

    9.8

    34,620

    117,947

    9.9

    37,546

    (1)
    The mineral reserves and mineral resources are estimated as at June 30, 2004 using
appropriate cut-off grades associated with an average long-term gold price of $325 per ounce.
The mineral resources are inclusive of mineral reserves.

    (2)
    The mineral reserve and mineral resource estimates are based on information prepared by or
under the supervision of H.G. Waldeck, Partner and Principal Mining Engineer of SRK Consulting
and Adrian Adams, Chief Geologist of the PDWAJV, respectively, who are Qualified Persons as
that term is defined in National Instrument 43-101 of the Canadian Securities Administrators.
H.G. Waldeck and Adrian Adams have verified the underlying data as appropriate in their
professional opinions (including sampling, analytical and test data).

    (3)
    Cut-off grades can vary depending on rock types, metallurgical processes and mining methods.
Cut-off grades are therefore quoted as a range to reflect the variability of these parameters.
The range of cut-off grades for South Deep is 5.00 to 7.40 grams per tonne for mineral
reserve estimates. A cut-off grade of 5.00 grams per tonne was used for mineral resource
estimates.

    (4)
    For further information regarding Placer Dome’s mineral reserve and mineral resource
estimations, refer to the notes to the Mineral Reserves, Reconciliation of Mineral Reserves,
Mineral Resources and Mineral Resources — Exploration Properties tables included in Placer
Dome’s Annual Report and Annual Information Form/Form 40-F for the year ended December 31,
2003.

Item 6.     Reliance on subsection 7.1(2) or (3) of National Instrument 51-102

                  Placer Dome Inc. is not relying on subsection 7.1(2) or (3) of National Instrument 51-102.

Item 7.     Omitted Information

                  There is no omitted information.

Item 8.     Executive Officer

                  J. Donald Rose

                  Executive Vice-President, Secretary and General Counsel

                  Telephone: (604) 682-7082

                  Fax: (604) 661-3703

Item 9.     Date of Report

                  August 4, 2004

    /s/ Geoffrey P. Gold

    Geoffrey P. Gold

    Vice-President, Assistant
Secretary

and Associate General Counsel

SIGNATURES

               Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly
caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

    PLACER DOME INC.

(Registrant)

    By:
    /s/ Geoffrey P. Gold

    Geoffrey P. Gold

    Vice-President, Associate General
Counsel

and Assistant Secretary

Date: August 5, 2004