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METALINE CONTACT MINES

W.3848 TURTLE PATCH ROAD

PINE RIVER, WISCONSIN 54965

December 12, 2005

H. Roger Schwall

Assistant Director

Division of Corporate Finance

U.S. SECURITIES AND EXCHANGE COMMISSION

Division of Corporate Finance

450 Fifth Street N.W.

Washington, D.C. 20549

    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. Schwall:

Reference is made to your comment letter, dated October 18, 2005, (hereinafter the “Comment
Letter”) regarding our annual report on Form 10-KSB for the year ended December 31, 2004, that we
received via facsimile on November 30, 2005.

We have an immediate concern with the 10-day response time requirement in the Content Letter; we
only received it on November 30th. So, unless otherwise advised, we will assume our response to
the Comment Letter will be timely if properly filed with your good
offices on or before December 14, 2005.

We respectfully request that the revisions we are proposing in this letter be made in our upcoming
annual report on Form 10-KSB for the year ended December 31, 2005. We make this request for the
following reasons:

    1.

    It is now time to begin preparing for our
upcoming annual report on Form 10-KSB for the
year ended December 31, 2005.

    A similar timing issue arose shortly after we first became effective in 2000. In that
particular case, we needed to file a post effective amendment to our 10-SB, while simultaneously
preparing to file our initial 10-KSB filing. It was agreed that the 10-KSB would satisfy both requirements.

    2

    We are a small business. Submitting an amended
Form 10-KSB in its entirety for the
subject year, and shortly thereafter our 10-KSB for the year ended December 31, 2005, could
present an unnecessary burden on our human and financial resources.

    H. Roger Schwall, Assistant Director

U.S. SECURITIES AND EXCHANGE COMMISSION

    December 12, 2005

Page 2

With the above request in mind, we hereby submit the following changes and revisions pursuant to
your Comment Letter:

Accounting Comments

Controls and Procedures, page 12

    1.

    “Item 8A – Controls and
Procedures” in our Form 10-KSB will be revised to reflect the changes
you have requested in items 1, 2 and 3 of the Comment Letter. Please see Attachment “A” hereto
for a copy of the revisions.

Exhibit 31.1

    4.

    The 302 certifications will be revised as requested. Please see Attachment “B” hereto for a
copy of the revision.

Engineering Comments

General

    5.

    “Item 2 – Description of Property” in our
Form 10-KSB will be revised in its entirety. We
feel these revisions will address your comments in items 5, 6 and 7 of the Comment Letter, and
further clarify our mineral property holdings. Please see Attachment “C” hereto for
a copy of the revisions.

Regarding your comment to provide names, claims, or grant numbers, dates of recording and

expiration for our claims, please be advised that this information has been previously

provided, as follows:

    (a)

    With respect to the Pend Oreille/Metaline Zinc Mines, the requested
information is provided in “Exhibit A – Description of Property” to the Mining Lease
With Purchase Option, Exhibit 10(i) of our Form 10-SB, as amended, which became
effective on September 14, 2000.

    (b)

    With respect to the Golden Chest Mine, the requested information is provided
in “Exhibit A – Golden Chest Mine Properties” to the Exploration Agreement and Option
to Lease, Exhibit 10.5 of Form 10-KSB for the year ended December 31, 2003, filed by
New Jersey Mining Company, SEC File 000-28837.

    6.

    The map of the Golden Chest Mine properties is attached hereto in Attachment “D” and will be
inserted appropriately. A map of the Pend Oreille/Metaline Zinc Mines properties was included
in our original Form 10-SB filing, as amended, which became effective on September 14, 2000.

Pend Oreille/Metaline Zinc Mines

Golden Chest Mine

    7.

    As requested, all references to “inferred geologic resources” will be removed. Please see
Attachment “C” hereto.

    H. Roger Schwall, Assistant Director

U.S. SECURITIES AND EXCHANGE COMMISSION

    December 12, 2005

Page 3

Metaline Contact Mines (the “Company”) acknowledge that: (a) it is responsible for the adequacy
and accuracy of the disclosure in the filing; (b) staff comments or changes to disclosure in
response to staff comments do not foreclose the SEC from taking any action with respect to the
filing; and (c) the Company may not assert staff comments as a defense in any proceeding initiated
by the SEC or any person under the federal securities laws of the United States.

We thank you for your every consideration of our above request, and the revisions and additions
contained herein. We look forward to receiving your comments. In the event you have any questions
please feel free to contact me at 920-987-5317.

    Respectfully submitted,

METALINE CONTACT MINES

    By:

/s/ John W. Beasley

    John W. Beasley

    Secretary/Treasurer/CFO

ATTACHMENT “A”

Item 8A. CONTROLS AND PROCEDURES

Annual Evaluation of the Company’s Disclosure Controls and Internal Controls

As of December 31, 2005, the Company evaluated the effectiveness of the design and
operation of its “disclosure controls and procedures” (“Disclosure Controls”), and its
“internal controls and procedures for financial reporting” (“Internal Controls”). This
evaluation (the “Controls Evaluation”) was done under the supervision and with the
participation of management, including the Company’s Chief Executive Officer (“CEO”) and
Chief Financial Officer (“CFO”). Rules adopted by the SEC require that in this section of
the Annual Report the Company present the conclusions of the CEO and the CFO about the
effectiveness of it’s Disclosure Controls and Internal Controls based on and as of the date
of the Controls Evaluation.

CEO and CFO Certifications

Appearing immediately following the Signatures section of this Annual Report there are two
separate forms of “Certifications” of the CEO and the CFO. The second form of
Certification is required in accord with Section 302 of the Sarbanes-Oxley Act of 2002 (the
“Section 302 Certification”). This section of the Annual Report, which you are currently
reading, is the information concerning the Controls Evaluation
referred to in the Section 302 Certifications and this information should be read in conjunction with the Section 302
Certifications for a more complete understanding of the topics presented.

Disclosure Controls and Internal Controls

Disclosure Controls are procedures that are designed with the objective of ensuring that
information required to be disclosed in our reports filed under the Securities Exchange Act
of 1934 (“Exchange Act’), such as this Annual Report, is recorded, processed, summarized
and reported within the time periods specified in the Securities and Exchange Commission
(“SEC”) rules and forms. Disclosure Controls are also designed with the objective of
ensuring that such information is accumulated and communicated to our management, including
the CEO and CFO, as appropriate to allow timely decisions regarding required disclosure.
Internal Controls are procedures which are designed with the objective of providing
reasonable assurance that the Company’s (1) transactions
are properly authorized; (2) assets are safeguarded against unauthorized or improper use; and (3) transactions are
properly recorded and reported, all to permit the preparation of our financial statements
in conformity with generally accepted accounting principles.

Scope of the Controls Evaluation

The CEO/CFO evaluation of the Company’s Disclosure Controls and Internal Controls include a
review of the controls’ objectives and design, the controls’ implementation by the Company
and the effect of the controls’ on the information generated for use in this Annual Report.
In the course of the Controls Evaluation, management sough to identify data errors,
controls problems or acts of fraud and to confirm that appropriate corrective action,
including process improvements, were being undertaken. This type of evaluation will be
done on a quarterly basis so that the conclusions concerning controls effectiveness can be
reported in the Company’s Quarterly Reports on Form 10-QSB and
Annual Report on Form 10-KSB. The Company’s Internal Controls are
also evaluated on an on-going basis by it’s
independent auditors in connection with their audit and

A-1

review activities. The overall goals of these various evaluation activities are to
monitor our Disclosure Controls and our Internal Controls and make modifications as
necessary; our intent in this regard is that the Disclosure Controls and the Internal
Controls will be maintained as dynamic systems that change (including the improvements and
corrections) as conditions warrant.

Among other matters, the Company sought in its evaluation to determine whether there were
any “significant deficiencies” or “material weaknesses” in the Company’s Internal Controls,
or whether the Company had identified any acts of fraud involving personnel who have a
significant role in the Company’s Internal Controls. This information was important both
for the Controls Evaluation generally and because items 5 and 6 in the Section 302
Certifications of the CEO and CFO require that the CEO and CFO disclose that information to
our Board’s Audit Committee and to our independent auditors and to report on related
matters in this section of the Annual Report. In the professional auditing literature,
“significant deficiencies” are referred to as “reportable conditions”; these are control
issues that could have a significant adverse effect on the ability to record, process,
summarize and report financial data in the financial statements. A “material weakness” is
defined in the auditing literature as a particularly serious condition where the internal
control does not reduce to a relatively low level the risk that misstatements caused by
error or fraud may occur in amounts that would be material in relation to the financial
statements and may not be detected within a timely period by employees in the normal course
of performing their assigned functions. The Company also sought to deal with other
controls matters in the Controls Evaluation, and in each case if a problem was identified,
management considered what revision, improvement and/or correction to make in accord with
our on-going procedures.

In accord with SEC requirements, the CEO and CFO note that, since the date of the Controls
Evaluation to the date of this Annual Report, there have been no changes in Internal
Controls or in other factors that could affect Internal Controls, including any corrective
actions with regard to significant deficiencies and material weaknesses.

Conclusions

Based upon the Controls Evaluation, the Company’s CEO and CFO have concluded that its
Disclosure Controls are effective to ensure that material information relating to the
Company is made known to management, including the CEO and CFO, particularly during the
period when its periodic reports are being prepared, and that its Internal Controls are
effective to provide reasonable assurance that the Company’s financial statements are
fairly presented in conformity with generally accepted accounting principles.

A-2

ATTACHMENT “B”

Exhibit 31.1

CERTIFICATION PURSUANT TO

SECTION 302 OF THE SARBANES-OXLEY ACT OF 2002

I, Richard l. Howell, certify that:

    1.

    I have reviewed this annual report on Form 10-KSB of Metaline Contact Mines

    2.

    Based on my knowledge, the report does not contain any untrue statement of a material fact or
omit to state a material fact necessary to make the statements made, in light of the
circumstances under which such statements were made, not misleading with respect to the period
covered by this report;

    3.

    Based on my knowledge, the financial statements, and other financial information included in
the report, fairly present in all material respects the financial condition, results of
operations and cash flows of the small business issuer, the periods presented in this report.

    4.

    The small business issuer’s other certifying officer and I are responsible for establishing
and maintaining disclosure controls and procedures (as defined in Exchange Act Rules 13a-15(e)
and 15d-15(e)) for the small business issuer and have:

    (i)
    Designed such disclosure controls and procedures to ensure that material
information relating to the small business issuer, including its consolidated
subsidiaries, is made to us by others within those entities, particularly during the
period in which this annual report is being prepared.

    (ii)
    Nor required.

    (iii)
    Evaluated the effectiveness of the small business issuer’s disclosure
controls and procedures and presented in this report our conclusions about the
effectiveness of the disclosure controls and procedures, as of the end of the period
covered by this report based on such evaluations; and

    (iv)
    Disclosed in this report any changes in the small business issuer’s internal
control over financial reporting that occurred during the small business issuer’s most
recent fiscal quarter (the small business issuer’s fourth fiscal quarter in the case
of an annual report) that has materially affected, or is reasonably likely to
materially affect, the small business issuer’s internal control over financial
reporting; and

    5.

    The small business issuer’s other certifying officer and I have disclosed, based on our most
recent evaluation, to the small business issuer’s auditors and the audit committee of the
small business issuer’s Board of Directors (or persons performing the equivalent functions):

    (i)
    All significant deficiencies and material weaknesses in the design or
operation of internal control over financial reporting which are reasonably likely to
adversely affect the small business issuer’s ability to record, process, summarize and
report financial information; and

B-1

    (ii)
    Any fraud, whether or not material, that involves management or other
employees who have a significant role in the small business issuer’s internal control over
financial reporting.

Date: December 12, 2005

/s/   Richard L. Howell

    Richard L. Howell, Chief Executive Office

B-2

ATTACHMENT “C”

Item 2. DESCRIPTION OF PROPERTIES

PEND OREILLE/METALINE ZINC MINES

Location

The Company owns mineral rights and properties covering approximately 8,200 acres to fee
simple property, patented mining claims, and unpatented mining claims, located in the
Metaline Mining District, Pend Oreille County, in northeastern Washington State. The
Company refers to these mineral rights and properties collectively as the “Pend
Oreille/Metaline Zinc Mines”. They are accessed in various locations along State Highway
20 and State Highway 31 (paved state highways with year around access), then over numerous
unimproved dirt roads. There is no surface infrastructure or electrical power on or to the
properties.

Mineral Rights and Properties

Specifically, the Pend Oreille/Metaline Zinc Mines mineral rights and properties comprise
the following: mineral rights to 5,798 acres of fee simple property; mineral rights to 487
acres of patented mining claims, and 1,925 acres of unpatented mining claims.

Unpatented mining claims are claims on federal land in which an individual, corporation, or
other legal entity, by the act of a valid location under the mining laws of the United
States, has obtained a right to remove and extract minerals from the land, but where full
title of the land has not been acquired from the U.S. Government. The U.S. Bureau of Land
Management (“BLM”) administrates unpatented claims. To maintain unpatented mining claims,
the claimant must pay a $125 maintenance fee and incur