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   Filed by Automated Filing Services Inc. (604) 609-0244 - Linux Gold Corp. - Response Letter

    LINUX GOLD CORP.

    1103 – 11871 Horseshoe Way

    Richmond, B.C., V7A 5H5

October 31, 2005

    H. Roger Schwall, Assistant Director

    U.S. Securities and Exchange Commission

    Division of Corporate Finance

    100 F Street, N.E.

    Washington, DC 20549-7010

    Re:
    Linux Gold Corp. (the “Company”)

    Form 20-F for the Fiscal Year Ended February 28, 2005

    Filed August 29, 2005

    File No. 0-30084

Dear Mr. Schwall:

This letter responds to your letter dated September 16, 2005,
commenting on the Company’s financial statements and related disclosures
contained in its Form 20-F for the fiscal year ended February 28, 2005. The item
numbers in this response correspond to the numbered comments in your letter of
September 16, 2005.

Form 20-F for the Fiscal Year ended February 28, 2005 Item
15. Controls and Procedures, page 44 Controls and Procedures

    1.

      We have amended the 20-F to indicate that the evaluation
      of the effectiveness of the disclosure controls and procedures was done
      “as of the end of the period covered by this report, being February 28,
      2005.”

    2.

      We have amended the 20-F to clarify that our officers
      concluded that there have been no changes in our internal control over
      financial reporting that has materially affected our internal control over
      financial reporting.

Financial Statements, page F-1

General

    3.

      We entered the exploration stage effective March 2002
      upon the signing of an agreement to joint venture the Fish Creek mineral
      property. We had previously

H. Christopher Owings

October 31, 2005
Page 2

    suspended the Linux-based network business, and began to focus primarily
      on the resource business.

4. The financial statements have been amended to comply with
  SFAS No. 7.

Report of Independent Accounting Firm, page F-2

5. A revised Report of Independent Accounting Firm has been
provided.

Note 7, Common Stock, page F-13

6. A Statement of Stockholders’ Equity has been added to the
financial statements.

Item 19, Exhibits, page 46

7. We have amended the 20-F to provide the correctly worded
certifications required pursuant to Section 302 of the Sarbanes Oxley Act.

Engineering Comments

General

8. We have inserted a small-scale map showing the location and
access to our property, as required by Instruction 3(B) of Rule 102 of
Regulation S-K.

9. We have amended the 20-F to remove all references to mines,
adjacent or analogous properties, deposits, occurrences or exploration
activities by other companies outside of our properties.

10. We have removed the references to individual and company
names we previously cited in our 20-F.

Glossary of Mining Terms, page 4

11. We have amended our 20-F by removing the first paragraph in
the section “Glossary of Mining Terms”.

12. We have amended our 20-F by removing the definition of the
term “geological resources” from this section.

13. We have amended our 20-F by removing all “mineral resource”
and “mineral reserve” definitions from this section.

Risk Factors

    H. Christopher Owings

    October 31, 2005

    Page 3

14. We have amended our 20-F by adding a risk factor that
addresses the probability of an individual prospect ever having “reserves” and
being commercially viable is extremely remote, and, in all probability, our
properties do not contain any reserves, and any funds spent on exploration will
probably not be recovered.

Business Overview, page 15

15. We have amended our 20-F to indicate that we are an
exploration stage company and that there is no assurance that a commercially
viable mineral deposit exists on any of our properties, and that further
exploration will be required before a final evaluation as to the economic and
legal feasibility is determined.

16. We have amended our 20-F by discussing the phased nature of
the exploration process, where applicable, and the place in the process our
current exploration activities occupy. We have disclosed that we will make a
decision whether to proceed with each successive phase of the exploration
program upon completion of the previous phase and upon analysis of the results
of that program.

17. We have amended our 20-F to make it clear that even if we
complete our current exploration program and it is successful in identifying a
mineral deposit, we will have to spend substantial funds on further drilling and
engineering studies before we will know if we have a commercially viable mineral
deposit or reserve.

18. We have amended our 20-F in each description of a mineral
property to state that we have no reserves.

19. We have amended our 20-F to expand our disclosure about our
exploration plans for our properties, including the following:

  We have disclosed a brief geological justification for each of our
  exploration projects written in non-technical language.
  We have disclosed a breakdown of our exploration timetable and budget, as
    much as we currently are able, including estimated funds that will be required
    for each exploration activity, such as geophysics, surface drilling and the
    like for each of our properties.
  We have amended our 20-F to briefly outline the phases of any phased program
    planned for our properties.
  We have amended our 20-F to disclose how the exploration programs will be
  funded.
  We have amended our 20-F to disclose who will be conducting any proposed
  exploration work and provided a summary of their qualifications.

    H. Christopher Owings

    October 31, 2005

    Page 4

20. We have revised our 20-F in accordance with your
suggestions set out in this paragraph.

21. We have amended our 20-F to disclose the meaning of
“non-exclusive option” in our description of the Duna Choapa Norte Orebody and
La Barca Orebody.

Closing Comments

As requested, the following is a statement from the Company
acknowledging the following:

  The Company is responsible for the adequacy and accuracy of the disclosure
  in the filing of the Form 20-F and all amendments thereto;
  SEC staff comments or changes to disclosure in response to SEC staff
  comments do not foreclose the Commission from taking any action with respect
  to the filing; and
  The Company may not assert SEC staff comments as a defense in any
  proceeding initiated by the Commission or any person under the federal
  securities law of the United States.

In addition to filing this letter, we are concurrently filing a
20-F/A Amendment No. 1.

I would appreciate it if you would please contact our legal
assistant, Suzanne Foster at 604-828-2570 if you have any questions.

Very truly yours,

LINUX GOLD CORP.

    John Robertson

    President

    cc:
    April Sifford, SEC

    Gary Newberry, SEC