SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
BAKER & MCKENZIE

April 20, 2005
VIA EDGAR TRANSMISSION

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Mail Stop 0404
Washington, D.C. 20549-0404
Attention: Ms. Jill S. Davis

     RE:  Gold Reserve Inc.
          Form 20-F, Filed April 1, 2005
          File No. 001-31819

Ladies and Gentlemen:

On  behalf of our client, Gold Reserve Inc. (the "Company"),
set  forth  below is the initial response of the Company  to
the  comments contained in the Staff's letter to Mr.  Robert
A.  McGuinness,  Vice President - Finance & Chief  Financial
Officer, dated April 11, 2005, regarding the Form 20-F filed
April  1,  2005.  For ease of reference, the  comments  have
been  repeated  below, with the initial response  set  forth
below the comments.  The numbering below corresponds to that
used  in  the  Staff's  comment  letter.   The  Company  has
received no other comment letter from the Staff.

Form 20-F for the year ended December 31, 2004

11.  Differences Between Canadian and U.S. GAAP, page 57

       1.    We  note  your accounting under  Canadian  GAAP
       allows  for the capitalization of certain exploration
       costs.   However,  under  U.S.  GAAP,  the  costs  of
       acquiring   unproven   mining  properties   and   any
       exploration  costs should be expensed as incurred  in
       that   you  have  no  proven  and  probable  reserves
       relating  to  them that support cash flow projections
       or  fair value measures required by SFAS No.  144  to
       assess  the recoverability of such costs.  You should
       not  capitalize  mining costs under U.S.  GAAP  until
       you  are  in  the  development stage  as  defined  in
       Industry  Guide  7.   In  addition,  a  contract   is
       required  to  be  in  place to establish  proven  and
       probable reserves when there is not an active  market
       to   sell  the  minerals.   As  a  result,  we   have
       traditionally  required a sales contract  or  binding
       letter  of  intent  to  buy the  industrial  mineral,
       before  we  would accept proven and probable  reserve
       designation.  Based on your disclosures  on  page  52
       in  Note  3,  it  appears some, if not  all,  of  the
       capitalized  exploration  costs  should   have   been
       expensed under U.S. GAAP.  As your reconciliation  to
       U.S.   GAAP  in  Note  11  does  not  address   these
       accounting differences, revisions may be required  to
       appropriately  reflect these accounting  differences.
       Please  revise  your  disclosures  as  necessary   or
       supplementally   support  your  accounting   position
       under U.S. GAAP.

The  undersigned and Mr. McGuinness have held various  phone
conferences  with Ms. Jill Davis regarding the comments  and
the   Company's  preliminary  views  on  the  issues  raised
therein.  Having received insight into the Staff's comments,
the Company is preparing a formal response.  However, as  we
informed Ms. Davis, Mr. McGuinness has been at the Company's
properties  in  Venezuela since last  week  and  is  now  in
transit  back  to  the  United  States.   In  light  of  Mr.
McGuinness'  absence,  as  discussed  with  Ms.  Davis,  the
Company anticipates providing its detailed responses to  the
comments  contained in the Staff's letter to you early  next
week,  but  no  later than Wednesday, April  27,  2005.   In
advance  of  providing  you  a  detailed  response,  we   do
understand from our conversations with Ms. Davis that it has
been determined that the comment:

     "In  addition, a contract is required to  be
     in  place  to establish proven and  probable
     reserves when there is not an active  market
     to  sell the minerals.  As a result, we have
     traditionally required a sales  contract  or
     binding   letter  of  intent  to   buy   the
     industrial  mineral, before we would  accept
     proven and probable reserve designation."

is  inapplicable to the Company since its main  asset  is  a
gold  and copper property and there are established  markets
for trading gold and cooper.  As such, our detailed response
will not address further the comments raised thereby.

I  would appreciate it if you would please call me at  (713)
427-5018 should you have any questions, including as to  the
Company's  proposed timetable.  Thank you for your attention
to this matter.

Very truly yours,

/s/ Jonathan B. Newton

Jonathan B. Newton

cc: Mr. Robert A. McGuinness

</TEXT>
</DOCUMENT>