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July 7, 2011
 Via Email

Mr. Graham Briggs Chief Executive Officer Harmony Gold Mining Company Limited Randfontein Office Park CNR Ward Avenue and Main Reef Road Randfontein, South Africa, 1760
Re: Harmony Gold Mining Company Limited
 Form 20-F for Fiscal Year Ended June 30, 2010
Filed October 25, 2010 Response Letter Dated May 11, 2011 File No. 1-31545

Dear Mr. Briggs:
 We have reviewed your response letter 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, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
            Form 20-F for Fiscal Year Ended June 30, 2010

Operating and Financial Revi ew and Prospects, page 88
 Critical Accounting Policies and Estimates, page 88

 Carrying Value of Goodwill, page 89

 1. We note your response to prior comment one.  With respect to the Phakisha cash
generating unit, please provide us a copy of the discounted cash flow model used for
purposes of impairment testing for each of the last three years.  In addition, tell us the
actual amount of net cash flows realized duri ng such timeframe and discuss any material
variations between assumptions used in the model and actual results and events. Your

Mr. Graham Briggs Harmony Gold Mining Company Limited  July 7, 2011 Page 2

 discussion of material varia tions between assumptions used  and actual results should
include, but should not be limited to, price, ounces produced, grade, cash costs in total
and per ounce.
 Results of Operations, page 96

 2. We note your response to prior comment six.  It remains unclear why you are unable to
provide information regarding items within  your control that impact the quality and
potential variability of earnings and cash fl ow, so readers can ascertain the likelihood that
past performance is indicative of future perf ormance.  Such information could include,
but should not be limited to, operating inform ation such as production, operating costs,
taxes, etc.
 Engineering Comments

 Reserves page 28

 3. We note your response to our previous commen t number two.  Please reconcile for us the
Evander and Evander (below infrastructure) reserve reported in your FYE 2010 annual filing to the reserv e reported in your technical document.

4. Considering that under Industry Guide 7 a f easibility study is re quired prior to the
reporting of a reserve with the Commission, please tell us how you have made the determination that you have a mineral rese rve for your Evander South, Rolspruit, and
Poplar projects.

You may contact John Cannarella  at (202) 551-3337 or Mark  Wojciechowski at (202)
551-3759 if you have questions regarding comments  on the financial statements and related
matters.  You may contact John Coleman, Mi ning Engineer, at (202) 551-610 with any
engineering questions.  Please contact me at (202) 551-3489 with any other questions.
         S i n c e r e l y ,           / s /  E t h a n  H o r o w i t z  f o r           B r a d  S k i n n e r          Senior Assistant Chief Accountant