SecProbe.io

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										April 18, 2005
via facsimile and U.S. mail

Mr. Rodrigo Romo
SEC and Legal Counsel
Cream Minerals Ltd.
570 Granville Street, Suite 1400
Vancouver, British Columbia
Canada	A1

	Re:	Cream Minerals Ltd.
		Form 20-F, filed September 30, 2004
		File No. 000-29870

Dear Mr. Romo:

      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 the 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.

Engineering Comments

General

1. For the properties, provide the disclosures in future filings
as
required by Industry Guide 7 (b).  In particular, provide:
* The location and means of access to the properties.
* Any conditions that must be met in order to obtain or retain
title
to the property.
* A brief description of the rock formations and mineralization of
existing or potential economic significance on the properties.
* A description of the present condition of the properties.
* A description of any work completed on the properties.
* A description of equipment and other infrastructure facilities.
* The current state of exploration of the properties.
* The total cost of the properties incurred to date and planned
future costs.
* The source of power that can be utilized at the properties.
* If applicable, provide a clear statement that the properties are
without known reserves and the proposed program is exploratory in
nature.
Refer to Industry Guide 7 (b) (1)-(5) for specific guidance.
Industry Guide 7 can be reviewed on the Internet at
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7.

2. Insert a small-scale map showing the location, access and
political boundaries adjacent to the properties in future filings.
Note that SEC`s EDGAR program now accepts digital maps, so please
include these 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 you need addition assistance,
please
call Filer Support at 202-942-8900.  Otherwise, provide the map to
the staff for our review.

Geological Setting, Page 18

3. This document contains far too much detailed technical
information, which tends to obscure what is important to the
average
investor. In future filings perform the following:
* Present information in clear, concise sections, paragraphs, and
sentences easily understandable to the average reader.
* Whenever possible, use short explanatory sentences and bullet
lists.
* Avoid highly technical terminology.
* Use descriptive headings and subheadings.
* Minimize repetitive disclosure that increases the size of the
document but does not enhance the quality of the information.

Mineralization, Page 21

4. The fifth paragraph of the section discloses some undefined and
grab samples.  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
some
area.
* Refrain from reporting single soil sample values.
* Convert all ppb quantities to ppm quantities for disclosure.
Revise future filings accordingly.

5. Disclose the following in future filings:
* The nature of the ownership or interest in the property.
* Any other underlying agreements or interests in the property.
* Indicate whether the mining claims are State or Federal claims.
* Provide names, claim, or grant number, date of recording and
expiration date, so the claims can be distinguished from other
claims
in the area
* Disclose the conditions the company must meet to keep these
claims.
* Disclose the area of the claims, either in hectares or acres.
Revise to fully discuss the material terms of the land or mineral
rights securing agreements.  Refer to paragraph (b) (2) of
Industry
Guide 7.

6. This filing refers to mines and other mineral properties that
exist in the area of companies` property.  This may allow
investors
to infer that the property may have commercial mineralization,
because of its proximity to these mines and properties.  In future
filings remove information about mines, prospects, or companies
operating in or near to your property.  Focus your disclosure on
the
company`s property.

7. To the extent that the web site contains disclosure about
adjacent
or other properties on which the company has no right to explore
or
mine, include the following language along with the following
cautionary note, including the bolding and indenting:
"This web site also contains information about adjacent properties
on
which we have no right to explore or mine.  We advise U.S.
investors
that the SEC`s mining guidelines strictly prohibit information of
this type in documents filed with the SEC.  U.S. investors are
cautioned that mineral deposits on adjacent properties are not
indicative of mineral deposits on our properties."

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)
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
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Mr. Rodrigo Romo
Cream Minerals Ltd.
April 19, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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