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								September 23, 2005

Mr. Paul Fulton
Chief Financial Officer
Lihir Gold Limited
7th Floor, Pacific Place
Cnr Champion Parade, Musgrave Street
Port Moresby, Papua new Guinea

	Re:	Lihir Gold LimitedHhlkjldkfjonl
		Form 20-F for Fiscal Year Ended December 31, 2004
		Filed June 30, 2005
		File No. 0-26860

Dear Mr. Paul Fulton:

      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.

Form 20-F for the Fiscal Year Ended December 31, 2004

Description of Operations

Overview, page 17

1. We note your disclosure that indicates production will drop
after
the mining period to approximately 300,000 ounces per year.
Please
clarify to us how you arrived at this estimate.  We note that the
estimated contained ounces in your stockpiles are 3.3 million
ounces
and the stockpile processing period is estimated to exceed 20
years.

Reserve Estimates, page 28

2. Please expand your reserve disclosure to provide additional
information concerning your stockpiles.  Specifically, provide a
breakdown of tons, average grade and contained ounces by low,
medium
and high grade categories.

Item 15. Controls and Procedures

3. We note that the language in Item 15, controls and procedures,
does not appear in accordance with Item 307 of Regulation S-K or
SEC
Release No. 33-8238.  For example, your evaluation of disclosure
controls should specifically indicate that your evaluation
occurred
as of the end of the period.  Please revise your disclosure
accordingly, if true.

Financial Statements

Statement of Cash Flows, page F-5

4. We note that your presentation of operating cash flows
aggregates
operating cash flows, such as those described in paragraph 14 of
IAS
7, into general captions of "Receipts from operating activities"
and
"Payments arising from operating activities".  Based on your
business
operations it may be helpful to expand your line item classes
under
your caption of operating cash flows into more meaningful
classifications for instance cash payments for services, cash
payments related to production (deferred mining costs), and cash
payments to employees to enhance investor understanding.

Note 1: Statement of Significant Accounting Policies, page F-6

Mine Properties, page F-6

5. We note that you are using proven and probable reserves as your
base for amortization of capitalized mine costs.  Please clarify
to
us and in your disclosure whether the base is represented by total
proven and probable reserves or developed proven and probable
reserves.

6. We note that you use the units of production method to amortize
a
portion of your capital assets.  Expand your disclosure to clarify
when a unit is considered to be "produced" to trigger recording
depreciation, depletion and amortization expense.  Note that for
U.S.
GAAP purposes, an item is considered to be "produced" for purposes
of
calculating your depreciation, depletion and amortization at the
time
it is physically removed from the mine.  These costs should then
be
classified as inventory and subject to inventory valuation in
accordance with ARB 43 for US GAAP.  Note that this was addressed
in
a discussion of stockpiled inventory at the Appendix to November
25,
2002 International Practices Task Force meeting.  Highlights for
this
meeting can be located at: http://www.aicpa.org/download/
belt/2002_11_25.pdf.  If you require additional clarification,
please
contact us at your convenience.

      Deferred mining costs, page F-7

7. Please expand your disclosures within your significant
accounting
policies to address the following regarding your deferred mining
costs:

* Disclose how you evaluate deferred stripping costs for
impairment.

* Disclose the waste ratios used for each income statement period
as
well as the actual ratios incurred for each period presented.  In
addition, please quantify the deferred assets attributable to each
pit.

* Explicitly state that the accounting for stripping costs
smoothes
the cost of waste-rock removal over the life of the mine.

* Disclose the year that the deferred costs and credits are
expected
to be fully amortized.

* Disclose the amount of deferred stripping costs or credits
amortized for each period presented.

* Disclose that there is mixed accounting practice among industry
participants in this area and that some mining companies expense
waste removal costs as incurred, which results in greater
volatility
reflected in the results of operations from period to period.

* If you have included deferred stripping costs in your
determination
of investing cash flows, for U.S. GAAP purposes we believe you
should
revise your consolidated statements of cash flows to report the
cash
activity associated with deferred stripping as a component of
operating cash flows.  Please refer to Appendix A of the November
2002 International Practices Task Force Meeting Highlights.

* Add discussion in your operating and financial review and
prospects
to identify changes in this ratio from period to period, explain
why
the changes occurred and the impact to your financial results.

* Modify your disclosure to indicate the amount of deferred
stripping
costs that relate to the pre production period and those that
relate
to the period since production commenced.

8. Tell us why you believe that deferred stripping costs incurred
in
either the pre or post production period represent assets in
accordance with IFRS.

9. Tell us whether your stripping costs are being recorded as a
component of inventory at any point in the earnings process.  In
addition, please clarify to us your accounting for deferred
stripping
in periods where the waste to ore ratio is less than average.  It
appears from your disclosure that such amounts are being expensed
directly rather than first being recognized as a component of
inventory.

10. Tell us why you believe your change from a phase basis to a
pit
basis of accounting for stripping costs is preferable under both
IFRS
and U.S. GAAP.  Tell us why you believe this change is consistent
with the componentization concept of IAS 16.

Mine buildings, plant and equipment, page F-8

11. We note your disclosure regarding your depreciation policy
suggesting that 90% of your plant and equipment is depreciated
over
40 years on the units of production method.  Please clarify
whether
any of your assets are being depreciated over a longer period than
their estimated useful life.

12. The economic lives of your assets and your related
amortization
and depletion policies are unclear to us.  It appears your mining
activities will cease in approximately 16 years and an additional
20
years of stockpile processing will occur thereafter.  Your
disclosure
indicates a remaining life of mine of approximately 40 years.
Please
clarify to us and in your document, what assets if any are being
amortized over the remaining mining period as well as those that
are
being amortized over the approximate 40 year total production
period.

Inventories, page F-8

13. Please clarify to us how you are attributing depreciation and
amortization to inventory.

Impairment of assets, page F-9

14. Please disclose your property, plant and equipment asset
revaluation accounting policy.  Refer to paragraph 31 to 42 of IAS
16.

15. We note your impairment recovery which contributed
approximately
62% to your net income for fiscal year 2004.  Although you have
generally described your valuation method, certain assumptions
such
as adjustments to your life of mine and reserves, remain unclear.
Please provide us with an analysis of your changes in critical
assumptions that support your impairment reversal and demonstrate
how
those assumptions are reasonable.

16. We note your recoverability testing that compares your
carrying
amounts to the value in use amount.  Please tell us how your value
in
use amounts compare to fair value as required by paragraph 7 of
SFAS
144 for U.S. GAAP.  Tell us and disclose if material, the amount
of
any U.S. GAAP difference that results from these two values.

17. We note your assumption of gold price of $380 per ounce in
your
impairment analysis.  Please tell us why you believe this price is
appropriate.  We note from your hedging portfolio disclosures that
your gold price realization for substantial amounts of your future
production is an average of approximately $330 per ounce.  We also
note your use of $380 per ounce for reserve determination.  Please
explain to what extent if any, you have considered your hedges in
your price assumptions for both impairment and reserve
determinations.

Revenue recognition, page F-11

18. We note your policy disclosure describing that revenue is
recognized when title and risk have passed to the customer,
although
you do not describe the types of contractual arrangements you have
with your customers. Your disclosures also suggest some
variability
might accompany the terms under which you sell your product,
although
we note you indicate it can be reliably measured.  It appears you
should expand your disclosures to clearly describe your
contractual
arrangements regarding delivery terms, pricing terms, and when
title
coveys. Additionally identify any estimates used in recognizing
revenue along with any underlying assumptions. Finally, indicate
whether or not your sales arrangements contain any provisional
pricing.  For US GAAP refer also to SAB Topic 13 and Topic VII of
the
September 25,  2002 AICPA SEC Regulations Committee meeting
highlights (http://www.aicpa.org/download/belt/2002_09_25_
highlights.pdf).

Note 15: Income Taxes, page F-22

19. We note your disclosure appears to indicate you have a
deferred
tax liability as of December 31, 2002. However, we were unable to
locate the presentation of that liability on your balance sheet.
Please tell us how you have characterized this liability or why it
is
inappropriate to include this in your balance sheet presentation.

20. We note that the significant components of your deferred tax
assets and liability are not described for each period presented.
Accordingly, please expand your disclosures to provide investors
with
an understanding of the nature of these assets and liabilities for
each period presented.

21. We note that you did not address the expected impact EITF 04-
06
Accounting for Stripping Costs in the Mining Industry will have on
future filings. Please expand your disclosures accordingly. See
SAB
Topic 11M.

22. We note that your disclosures indicate differences between
IFRS
and U. S. GAAP without providing a clear description of the
applicable U. S. GAAP which would apply.  For example, but without
limitation, we note the following:

* The circumstances under which interest is capitalized for U. S.
GAAP purposes is unclear. For example, you refer to an "available
interest concept" which may not be understood by U. S. investors.

* The differences in depreciation methods which you refer to as
"two
bases of accounting" without further explanation what you mean,
and
describing the principles that would apply under U. S. GAAP.

* The differences in impairment measurement principles and
application under U. S. GAAP.

We believe you will need to expand your disclosures where
significant
accounting policies differ to describe, in sufficient detail, the
accounting applied under U. S. GAAP.

23. Please describe to us the error in which you determined
capitalization of deferred stripping costs was appropriate under
U.
S. GAAP.  Although we recognize variations of accounting for
deferred
costs exists in practice between mining industry participants, it
is
unclear whether this error was a result of a change in policy or
whether you had been following a consistent policy since inception
of
deferring your stripping costs.  In the event this was an error in
which previously audited financial statements had been issued we
believe you will need to re-label the appropriate column headings
and
line items as being "restated".

24. We note that you have not included the required disclosures
under
SFAS 143 in connection with your long-lived asset retirement
obligation. Please expand your disclosures accordingly or tell us
why
you believe this disclosure would not apply.  Refer to paragraph
22
of SFAS 143.

25. We note your reconciliation does not disclosure the accounting
principles used to account for other comprehensive income and the
components thereof.  It appears you should expand your disclosures
in
this regard and characterize the appropriate unrealized foreign
currency translation and derivative adjustments as a component of
other comprehensive income. Refer to SFAS 130.

26. To the extent your income tax disclosure under IFRS does not
provide the detail disclosure required by SFAS 109 related to your
deferred tax assets and liabilities for all periods presented, we
believe you will need to expand your U. S. GAAP reconciliation
footnote accordingly. In this regard we note that note 15 only
appears to disclose the components of your deferred tax asset and
liability as of the end of fiscal year 2004.

Engineering Comments

General

27. Insert a small-scale map showing the location and access to
the
property.  Note that SEC`s EDGAR program now accepts digital maps,
so
please include these maps in any future 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 the figures and/or diagrams to appear in the right
location when the document is viewed on the Internet.  For more
information, please consult the EDGAR manual, and if addition
assistance is required, please call Filer Support at 202-942-8900.
Otherwise, provide the map to the staff for review.

Reserves, page 28

28. The cutoff grade is a critical component used to evaluate the
potential of the mineral properties. Disclose the operating costs
and
recovery parameters used to determine the cutoff grade estimate.
Show that this calculation demonstrates the cutoff grade or tenor
used to define a mineral resource has reasonable prospects for
economic extraction.  In establishing the cut-off grade, it must
realistically reflect the location, deposit scale, continuity,
assumed mining method, metallurgical processes, costs, and
reasonable
metal prices.

Exploration, page 30

29. Expand the disclosure concerning the exploration plans for the
properties.
* Disclose a brief geological justification for each of the
exploration projects written in non-technical language.
* Give a breakdown the exploration timetable and budget, including
estimated amounts that will be required for each exploration
activity, such as geophysics, geochemistry, surface sampling,
drilling, etc. for each prospect.
* If there is a phased program planned, briefly outline all
phases.
* Alternatively, disclose there are no current detailed plans to
conduct exploration on the property.
* Disclose how the exploration program will be funded.
* Identify who will be conducting any proposed exploration work,
and
discuss what their qualifications are.

30. We recommend that a brief description of the QA/QC protocols
be
provided to reassure the investors regarding sample preparation,
controls, custody, assay precision and accuracy.  This would apply
to
exploration and operational analytical procedures.

Closing Comments

       As appropriate, please amend your filing and respond to
these
comments within 10 business