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	August 9, 2005

Mail Stop 4561

VIA U.S. MAIL AND FAX (604) 628-4628

Mr. Hans Boge
President
Klondike Star Mineral Corporation
1031 Ten Mile Road
Whitehorse, YK
Canada  1YA 7A2

Re:	Klondike Star Mineral Corporation
      Form 10-KSB for the year ended February 28, 2005
      Filed June 15, 2005
      File No. 000-30965

Dear Mr. Boge:

      We have reviewed your July 26, 2005 response letter and have
the following additional comments.

1. We read your response to comment 2.  Please clarify why you
subtracted $1.00 per option share in arriving at the compensatory
value of $0.11 per option share.  Did you issue 1.2 million
separate
option contracts which, in effect, results in an exercise price of
$3.50 per share?  If so, please revise your Black-Scholes option-
pricing model since this will result in a valuation different than
$0.11 per option share.  If not, please explain to us why you are
subtracting $1.00 from each option share.

2. Based on the schedule provided in response to comment 3 we
cannot
tell how you have calculated your volatility.  In addition, you
did
not provide us with an explanation of your basis for estimating
your
volatility.  As such, we reissue our prior comment 3.  Estimated
expected long-term volatility generally begins with calculating
historical volatility for a similar long-term period, five years
in
this instance, and then considering the effects of ways in which
the
future is reasonably expected to differ from the past.  If
historical
volatility is not available for your common stock over a period
that
is commensurate with the expected option life, you should consider
the pattern and level of historical volatility of more mature
entities during the initial years those entities were publicly
traded.  Please tell us how you considered paragraphs 277 and 284-
285
of SFAS 123.

3. Please provide us with the calculation of your historical
volatility of 12.41% referred to in your response to comment 3.

*  *  *  *

	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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,

      Steven Jacobs
      Accounting Branch Chief
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Mr. Hans Boge
Klondike Star Mineral Corporation
August 9, 2005
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