SecProbe.io

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								July 6, 2005

Mr. Ketan Panchmatia
Vice President, Finance and Chief Financial Officer
Gentry Resources Ltd.
101 6th Avenue S.W.
Suite 2500
Calgary, Alberta, Canada T2P 3P4

	Re:	Gentry Resources Ltd
		Form 40-F for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
		File No. 0-29878

Dear Mr. Panchmatia:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  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 information so we may better understand
your
disclosure.  After reviewing this information, we may 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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

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

General

1. We note that you state on page 3 of your 40-F that you own a
13%
interest in the outstanding common equity of Stratic Energy
Corporation, which participates in oil and gas exploration and
development activities in, among other places, Syria.  In light of
the
fact that Syria has been identified by the U.S. State Department
as a
state sponsor of terrorism, and is subject to economic sanctions
administered by the U.S. Treasury Department`s Office of Foreign
Assets Control, please describe for us your past and present
contacts
with Syria; advise us of their materiality to you; and give us
your
view as to whether they constitute a material investment risk for
your
security holders.  In preparing your response please consider that
evaluations of materiality should not be based solely on
quantitative
factors, but should include consideration of all factors,
including
the potential impact of corporate activities upon a company`s
reputation and share value, that a reasonable investor would deem
important in making an investment decision.

In note 2 (c) to your consolidated statement of cash flows, you
state
that during October 2003 you ceased to exert significant influence
on
your investment in Stratic.  In note 4 you state that you are
"related
to Stratic by virtue of common directors and officers."  Please
explain to us the basis for your statement that you ceased to
exert
significant influence on your investment in Stratic during 2003.

Consolidated Financial Statements, Exhibit B

2. Please include an accountants` report in your Form 40-F
covering
the periods presented.

Notes to Consolidated Financial Statements, Exhibit B

Summary of Significant Accounting Policies

Revenue Recognition,

3. We note that your accounts receivable balance of $12,808,282 at
December 31, 2004 represents approximately 50% of your 2004
revenue of
$25,452,001.  Given that your accounts receivable represents such
a
large portion of your revenue, please tell us how you satisfy the
criteria that ultimate collection is reasonably assured prior to
your
recognition of revenue.  In your response, please quantify the
amount
of credits granted to customers during 2004 and 2003, and
supplementally provide to us an accounts receivable aging
analysis.
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
the
amendment to expedite our review.  Please furnish a cover letter
with
your amendment that keys your responses to our comments and
provides
any requested 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 to be certain that the
filing
includes all information required under the Securities Exchange
Act of
1934 and that they have provided all information investors require
for
an informed investment decision.  Since the company and its
management
are in possession of all facts relating to a 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 Ryan Milne at (202) 551-3688, or me at (202) 551-
3684,
if you have questions regarding comments on the financial
statements
and related matters.

								Sincerely,

								April Sifford
								Branch Chief

cc: 	Mr. Ryan Milne
Mr. Ketan Panchmatia
Gentry Resources Ltd.
July 6, 2005
Page 1

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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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