SecProbe.io

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Mail Stop 7010

                  October 18, 2005

John W. Beasley
Metaline Contact Mines
Secretary/Treasurer/CFO
W. 3848 Turtle Patch Road
Pine River WI 54965

      Re:	Metaline Contact Mines
		Form 10-KSB for the Year Ended December 31, 2004
		Filed on March 25, 2005
      File number 0-31025

Dear Mr. Beasley:

      We have reviewed your filings and have the following
comments.
We have limited our review of your filings 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 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Accounting Comments

Form 10-KSB for the Year Ended December 31, 2004

Control and Procedures, page 12

1. Please note that Item 307 of Regulation S-B requires an
evaluation
of the disclosure controls and procedures to be performed "as of
the
end of the period" covered by the quarterly or annual report,
rather
than "as of a date within 90 days of the filing date" of the
quarterly or annual report.  Please perform the evaluation as of
the
end of the period covered by the quarterly or annual report, and
revise your disclosure accordingly.

2. Please remove the paragraph under Limitations of the
Effectiveness
of Controls and the reference made to this paragraph in the
Conclusions section on page 14.

3. Please indicate whether there were any changes to internal
controls over financial reporting as opposed to only the
"significant" changes.  Please refer to paragraph (c) of Item 308
of
the Regulation S-B.

Exhibit 31.1

4. Please revise the certification to be consistent with the
language
specified under Instruction 31 to Item 601 of Regulation S-B.
Please
ensure that this change is also reflected in your quarterly
filings.

Engineering Comments

General

5. Disclose the following:

* Indicate whether the mining claims are State or Federal claims.
* Provide names, claim, or grant number, date of recording and
expiration date, so your claims can be distinguished from other
claims in the area.
* Disclose the conditions you must meet to keep these claims.
* Disclose the area of your claims, either in hectares or acres.

Revise to fully discuss the material terms of your land or mineral
right securing agreements.  Refer to paragraph (b) (2) of Industry
Guide 7.

6. Insert a small-scale map showing the location and access to
your
property.  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.

Pend Oreille/Metaline Zinc Mines, page 5

Golden Chest Mine, page 7

7. Industry Guide 7 does not allow the disclosure of "inferred
geologic resources". Please remove your disclosure about 230,000
ounces of gold in that category.

		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 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 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 Yong Choi at (202) 551-3758, April Sifford,
Branch Chief at (202) 551-3684, if you have questions regarding
comments on the financial statements and related matters. You may
contact Ken Schuler Mining Engineer at (202) 551-3718 with
questions
about engineering comments.   Please contact me at (202) 551-3740
with any other questions.

Sincerely,

H. Roger Schwall
Assistant Director
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John W. Beasley
Metaline Contact Mines
October 18, 2005
Page 1

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

         DIVISION OF
CORPORATION FINANCE

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