SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>

							April 1, 2005

via facsimile and U.S. mail

Mr. F. John Norman
Chief Financial Officer
Pacific Rim Mining Corp.
Suite 410 - 625 Howe Street
Vancouver, BC
Canada	V6C 2T6

	Re:	Pacific Rim Mining Corp.
		Form 20-F, filed August 18, 2004
		File No. 001-13812

Dear Mr. Norman:

      We have reviewed the above filing and have the following
accounting and engineering comments.  Our review has been limited
to
your financial statements and the related disclosures in Operating
and Financial Review and Prospects.  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 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.

20-F for the fiscal year ended April 30, 2004

Accounting Comments

General

1. On page one of your 2004 Form 20-F, the commission file number
on
this filing refers to the Dayton Mining Corporation.  Please
correct
the commission file number to reflect the present company.

Financial Statements, page 74

Report of Independent Registered Public Accounting Firm, page F-3

2. We note that your accountant`s report covers each of the two
fiscal years ended April 30, 2004, and the four months ended April
30, 2002.  As you know, you are required to file audited
statements
of income and cash flows for each of the three fiscal years
preceding
the date of the most recent audited balance sheet under Rule 3-
02(a)
of Regulation S-X.  Although it appears you included statements of
income and cash flows for the year ended December 31, 2001 in an
effort to comply with this guidance, we are unable to locate the
separate report of the other auditor in your filing.  Since there
is
no disclosure or labeling to suggest the information related to
2001
is unaudited, it will be necessary to amend your filing to include
the other auditor`s report, provided that auditor is willing to
reissue the opinion, or to otherwise label such information as
unaudited until you are able to make other arrangements.

Engineering Comments

Resources, Pages 22-24

3. 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 measured and indicated resources separately from
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
silver.  All metal equivalent calculations should be clearly
documented and footnoted to insure all assumptions are apparent to
the average investor.  The relative quality, reliability, and risk
associated with each group of estimates must be clearly
distinguished
and conveyed to the average non-technical reader.

In future filings, 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.

In future filings, 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.

4. With regard to the Andacollo Mine in Chile, operations were
suspended September 30, 2000, due to low metal prices.  Presently,
45
of the 118 full-time employees or 38% of the company`s full-time
personnel are posted at this operation.  Disclose in future
filings
the status of this mine, any resultant production, costs, and the
impact closure would have on the company.  Also clarify whether
any
reportable resources or reserves are located at this mine and, if
so,
document that conclusion.

5. Under CIM guidelines, "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."  In future filings, disclose the cutoff grades
used
to delimit the tonnage estimates.  Also, disclose an analysis that
substantiates that the cutoff grades used were based on reasonable
economic assumptions.  Or if the resource estimates are not based
on
economic cutoffs, remove the estimates.

6. As discussed in detail in another comment, Canadian
incorporated
companies may disclose mineral reserve and mineral resource
estimates
that are not consistent with those defined in Industry Guide 7;
however, they still must disclose reserve estimates consistent
with
Industry Guide 7 and reconcile the two reserve estimates.
Additionally, Canadian and Industry Guide 7 definitions for
mineral
reserves are substantially different.  It is the staff`s position
that:

* A "final" or "bankable" feasibility study is required to meet
the
requirements to designate reserves under Industry Guide 7.
* The historic three year average price is to be used in any
reserve
or cash flow analysis to designate reserves.
* To meet the "legal" part of the reserve definition, the primary
environmental analysis or document should have been submitted to
governmental authorities.

Revise your definitions in future filings.

7. We note that your website and some press releases refer to or
use
the terms "measured," "indicated," and "inferred," "resources."
If
you continue to make references on your web site or press releases
to
reserve measures other than those recognized by the SEC, accompany
such disclosure with the following cautionary language, including
the
bolding and indenting:

Cautionary Note to U.S. Investors -- The United States Securities
and
Exchange Commission permits U.S. mining companies, in their
filings
with the SEC, to disclose only those mineral deposits that a
company
can economically and legally extract or produce.  We use certain
terms on this website (or press release), such as "measured,"
"indicated," and "inferred" "resources," that the SEC guidelines
strictly prohibit U.S. registered companies from including in
their
filings with the SEC.  U.S. Investors are urged to consider
closely
the disclosure in our Form   , File No.      , which may be
secured
from us, or from the SEC`s website at
http://www.sec.gov/edgar.shtml.

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 Donald F. Delaney, staff accountant, at
(202)
824-5353 or, in his absence, Karl F. Hiller, (202) 942-1981, if
you
have questions regarding comments on the financial statements and
related matters.  Please contact George (Ken) Schuler, mining
engineer, at (202) 824-5527 or, in his absence, Roger Baer, mining
engineer, at (202) 942-2965, if you have questions regarding
engineering comments.  Please contact me at (202) 942-1870 with
any
other questions.  Direct all correspondence to the following ZIP
code:  20549-0405.

							Sincerely,

							H. Roger Schwall
							Assistant Director

??

??

??

??

Pacific Rim Mining Corp.
April 1, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

</TEXT>
</DOCUMENT>