SecProbe.io

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							July 12, 2005

via facsimile and U.S. mail

Mr. Duane Poliquin
President
Almaden Minerals Ltd.
750 West Pender Street, Suite 1103
Vancouver, British Columbia
Canada	V6C 2T8

	Re:	Almaden Minerals Ltd.
		Form 20-F, filed June 13, 2005
		File No. 000-28528

Dear Mr Poliquin:

      We have reviewed the above filing and have the following
engineering comments.  Our review has been limited to the areas
identified below.   Please provide us a response to the comments
and
include appropriate disclosure in future filings.  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 supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

The MOR Prospect - Canada, page 58
History and recent work, page 59

1. The last paragraph on page 59 refers to the Kudz-Ze-Kayah and
Wolverine deposits. Describe only geology, history, or exploration
results that are directly related to the properties that the
company
has the right to explore or mine.  Remove all references to mines,
adjacent or analogous properties, deposits, occurrences, or
exploration activities by other companies outside of the company`s
properties.

The Sam Prospect - Canada, Geology and mineralization, page 61

2. The first paragraph on page 62 refers to sample grades ranging
from and to.  As a general checklist, when reporting the results
of
sampling and chemical analyses:
*Disclose only weighed-average sample analyses 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 the highest values or grades of
sample
sets.
*Eliminate grades disclosed as "up to" or "as high as."
*Eliminate statements containing grade 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 readability of sample and
drilling
data.
*Soil samples may be disclosed as a weighted average value over
an
area.
*Refrain from reporting single soil sample values.
*Convert all ppb quantities to ppm quantities for disclosure.
Revise the filing accordingly.

The Logan Property - Canada, page 68
History and Recent Work - Canada, page 69

3. Inferred resources are disclosed on pages 68 and 69 as project
was
evaluated.  Mineral resources must have "reasonable prospects for
economic extraction."  This means that any reportable "resource"
estimates must have been delimited using an economically based
cutoff
grade to segregate resources from just mineralization. Disclose
the
cutoff grade used to delimit the tonnage estimates.  Also,
disclose
the analysis and relevant factors that substantiate the cutoff
grades
used were based on reasonable economic assumptions. The relevant
factors must realistically reflect the location, deposit scale,
continuity, assumed mining method, metallurgical processes,
operational and capital costs, and reasonable metal prices based a
historic three-year average, as defined by the fiscal reporting
period.  Or if the resource estimates are not based on economic
cutoffs, remove the estimates.

4. It is very important to clearly distinguish between "Reserves,"
which have a clearly defined technical, legal, and economic
meaning
and "Non-reserve" mineralization that may or may never be mined at
a
profit for various reasons.  In addition, within a "Non-Reserve"
section, disclose the measured and indicated resources separately
from the inferred resources, using separate tables and narratives.
Resources should only be reported as "in place" tonnage and grade,
and should not be disclosed as units of product, such as ounces of
gold or pounds of copper.  The relative quality, reliability, and
risk associated with each group of estimates must be clearly
distinguished and conveyed to the average non-technical reader.

Before the Measured and Indicated Resource table, insert the
following including the indenting and bolding:

Cautionary Note to U.S. Investors concerning estimates of Measured
and Indicated Resources.  This section uses the terms "measured"
and
"indicated resources."  We advise U.S. investors that while those
terms are recognized and required by Canadian regulations, the
U.S.
Securities and Exchange Commission does not recognize them.  U.S.
investors are cautioned not to assume that any part or all of
mineral
deposits in these categories will ever be converted into reserves.

Before the Inferred Resource table, insert the following including
the indenting and bolding:

Cautionary Note to U.S. Investors concerning estimates of Inferred
Resources.
This section uses the term "inferred resources."  We advise U.S.
investors that while this term is recognized and required by
Canadian
regulations, the U.S. Securities and Exchange Commission does not
recognize it.  "Inferred resources" have a great amount of
uncertainty as to their existence, and great uncertainty as to
their
economic and legal feasibility.  It cannot be assumed that all or
any
part of an Inferred Mineral Resource will ever be upgraded to a
higher category.  Under Canadian rules, estimates of Inferred
Mineral
Resources may not form the basis of feasibility or pre-feasibility
studies, except in rare cases.  U.S. investors are cautioned not
to
assume that part or all of an inferred resource exists, or is
economically or legally minable.

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
amendments to expedite our review.  Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental 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 reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the 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 George (Ken) Schuler, mining engineer, at
(202)
551-3718 or, in his absence, Roger Baer, mining engineer, at (202)
551-3705, if you have questions regarding engineering comments.
Please contact me at (202) 551-3740 with any other questions.
Direct
all correspondence to the following ZIP code:  20549-7010.

							Sincerely,

							H. Roger Schwall
							Assistant Director
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Mr. Duane Poliquin
Almaden Minerals Ltd.
July 12, 2005
Page 2

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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