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Meridian Gold Inc.

9670 Gateway Drive

Suite 200

Reno, Nevada 89521-8953

(775) 850-3777

(775) 850-3733 Fax

December 9, 2005

United States Securities and Exchange Commission

Division of Corporate Finance

Washington, D.C. 20549-0405

    Re:

    Meridian Gold, Inc.

    Form 40-F for Fiscal Year Ended December 31, 2004

    Filed March 28, 2005

    Response Letter Dated November 18, 2005

    File No. 1-12003

     We received your letter dated November 30, 2005 concerning your comments on our annual report
on Form 40-F for the year ended December 31, 2004. We have prepared the following responses to
your comments. The Staff’s comments are shown in bold.

    •

    Please expand your disclosure to address the assumptions that management has made to
determine that they will be able to overcome local opposition to the Esquel project and have
it in production at optimum levels at the beginning of 2006.

     We will expand our disclosure in future filings to include the assumptions made by
management as to why we believe we will be able to overcome local opposition and ultimately be able
to place the project into production. We propose adding disclosure into our MD&A in our Form 40-F
for 2005 under the section Impairment Analysis of Assets (on page 22 of the 2004 Annual Report)
after updating the data for 2005:

“We assumed that we would be able to overcome local opposition by educating
the community on responsible mining and by developing a mine plan that addressed
their concerns such as replacing the previously proposed open-pit mine with an
underground mine and by improving the method used for disposal of tailings.
Management remains confident that all necessary permits will ultimately be
obtained.”

     At the time of filing our 2004 Form 40-F, we believed that during the next fiscal year, we
would either obtain or make significant progress towards obtaining the necessary permits to operate
the mine.

    •

    Explain why your 2003 impairment analysis did not result in the measurement of fair
value or an impairment charge.

     Our 2003 impairment analysis indicated that expected future cash flows were in excess of
net carrying value. The technical report on the property that was prepared in March 2003 and filed
on SEDAR in May 2003 included an economic analysis based only on proven and probable reserves, as
required under National Instrument 43-101, and did not include known resources. If known resources
had been included in the economic analysis presented in the technical report, as they were in the
2003 year-end impairment analysis, then the undiscounted future cash flows would have exceeded the
carrying value of the project.

    •

    Explain why there is a difference between the purchase price used in your impairment
analysis and the net book value of the Esquel Project of $558.8 million, as disclosed on page
32 of your annual report.

     The primary differences between the $310 million net purchase price used in our
impairment analysis and the net book value of total mineral property, plant and equipment related
to the Esquel Project of $558.8 million as at December 31, 2004 are the deferred tax liability
recorded at the time of acquisition as required under CICA HB 3465 and FAS 109 and as adjusted for
currency translation changes as required under CICA HB 1650 and FAS 52 ($175.7 million at December
31, 2004) and cumulative currency translation gains reflected in shareholders equity ($62.3 million
at December 31, 2004).

     Because our impairment analysis was performed on an after-tax basis, we compared the resultant
future cash flows per our impairment analysis to the Company’s net investment in the Esquel Project
to determine whether expected future cash flows were in excess of carrying value.

     If you should have any additional questions after reviewing our responses please contact us.
If we have adequately responded to your questions, please confirm in writing that the file is
closed.

    Sincerely,

    /s/ Peter C. Dougherty

    Peter C. Dougherty

Vice President, Finance and Chief Financial Officer

    Meridian Gold Inc.