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August 3, 2023
Karl Hanneman
Chief Executive Officer
International Tower Hill Mines Ltd.
2710-200 Granville Street
Vancouver, BC, V6C 1S4
Canada
Re:International Tower Hill Mines Ltd.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed March 8, 2023
File No. 001-33638
Dear Karl Hanneman:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2022
General
1.Please utilize sequential and unique numbering on the pages in any amendment that is
necessary to resolve the concerns outlined in the comments that follow.
Financial Statements
Note 2 - Summary of Significant Accounting Policies, page FS-48
2.We note your disclosures on pages 81 and FS-49 stating that your mineral project "is
currently in the exploration and evaluation phase" which appears to be consistent with
disclosures on page 51, explaining that you expect to continue to incur losses in the
foreseeable future, expressing uncertainty as to whether you will ever begin production,
and clarifying that you do not consider the Livengood Gold Project to be commercially
viable based on the prevailing commodity prices.

 FirstName LastNameKarl Hanneman
 Comapany NameInternational Tower Hill Mines Ltd.
 August 3, 2023 Page 2
 FirstName LastNameKarl Hanneman
International Tower Hill Mines Ltd.
August 3, 2023
Page 2

However, these disclosures are not consistent with numerous disclosures elsewhere in
your filing indicating the property is in the development stage and having reported proven
and probable mineral reserves for the property.

Please clarify the nature of support for any disclosures of proven and probable reserves
that you believe should be retained, including the investment and market assumptions
made in formulating a view on economic viability and compiling your preliminary
feasibility study, and submit the revisions that you propose to clarify the status of the
property and to resolve the inconsistencies referenced above.
3.We note your disclosures on pages 81 and FS-49 describing various circumstances under
which you would test the costs capitalized for your mineral property for impairment,
which include "a current-period operating or cash flow loss combined with a history of
operating or cash flow losses," which is consistent with FASB ASC 360-10-35-21(e).

However, we do not see any disclosures of impairment as would be provided pursuant to
FASB ASC 360-10-50-2, or of the qualitative and quantitative information that would be
necessary to understand the estimation uncertainty and the impact the critical accounting
estimate has had or is reasonably likely to have on your financial condition or results of
operations, as would be required to comply with Item 303(b)(3) of Regulation S-K.

We understand that the amounts you have capitalized for the mineral property represent
acquisition costs incurred predominantly in 2006, 2011 and 2012, and that the balance has
remained relatively unchanged for over ten years. We see that the balance exceeds the net
present values associated with the Base Case disclosed on pages 19-7, 22-7, 22-7, and 138
of your pre-feasibility studies dated October 29, 2021, March 8, 2017, September 8, 2016,
and September 4, 2013, respectively, as calculated using a discount rate of 5%. We also
note disclosures on pages 51 and 67, explaining that you have incurred losses and have
had no revenue from operations since inception, which you indicate was in 1978, and that
you have not completed any material exploration on the property since 2012.

Given these various circumstances, it appears that you would need to have conducted
impairment testing in accordance with FASB ASC 360-10-35-29 through 35 on a periodic
basis for an extended period of time. Please describe to us the extent of any impairment
testing that you have conducted pursuant to this guidance since 2012, provide us with the
analyses that either were conducted or that will be conducted for recoverability as of the
end of your most recently completed fiscal year, and submit any revisions that you
propose to clarify your efforts and the results of your impairment testing in this regard.
4.We note your disclosure on page 51, referring to the document you filed as Exhibit
96.1, stating that although the Technical Report Summary underlying your disclosures of
proven and probable reserves indicates the project would generate "a minimal positive
return" using a gold price of $1,680 per ounce, the company "...would need to see higher
gold prices over a sustained period for the Project to be commercially viable."

 FirstName LastNameKarl Hanneman
 Comapany NameInternational Tower Hill Mines Ltd.
 August 3, 2023 Page 3
 FirstName LastNameKarl Hanneman
International Tower Hill Mines Ltd.
August 3, 2023
Page 3

As the definition of preliminary feasibility study in Item 1300 of Regulation S-K depends
on the qualified person having determined that extraction of the mineral reserve is
economically viable under reasonable investment and market assumptions, it is unclear
how your position with regard to the price that would yield a commercially viable
project would be consistent with reporting proven and probable reserves.  It is also unclear
how the Base Case that is shown on page 19-7 of the Technical Report Summary showing
an after-tax net present value of $44.6 million and an internal rate of return of 5.3%,
while assuming that the discount rate would be 5%, would need to change when using a
discount rate that is reflective of and consistent with the project uncertainties and risk.

Please consult with the qualified person involved in preparing the Technical Report
Summary regarding these observations and describe for us the assessments that were
made in considering these factors and establishing correlation between the discount rate
and the uncertainties and risk of the project; or explain to us how this would need to
change to reflect reasonable investment and market assumptions.

Please explain to us how you would reasonably expect to obtain financing for the project
based on the economics illustrated in the Base Case, if this is your view.
5.We note that your description of cash equivalents on page 49 encompasses "highly liquid
investments with original maturities of twelve months or less," which diverges from the
definition provided in the FASB Master Glossary, which generally includes only
investments with original maturities of three months of less.

Please submit the revisions that you propose to your financial presentation and the
associated disclosures elsewhere in the filing that would be necessary to conform with this
guidance, or explain to us why you believe it would not apply to you.
Exhibit 96.1 Livengood Gold Project, page 63
6.The Technical Report Summary that you have filed as support for your disclosures of
mineral resources and reserves does not include all of the content prescribed by Item
601(b)(96) of Regulation S-K. We have identified the information that should be provided
in the remaining comments in this letter. Please discuss these observations with the
qualified persons involved in preparing the report and arrange to obtain and file a revised
Technical Report Summary that includes all of the required information.

You may submit a draft of the revised report for review prior to filing your amendment.
Section 6 - Geological Setting and Mineralization and Deposit
6.1.2 Mineralization and Alteration, page ES-6
7.At least one stratigraphic column is required to comply with Item 601(b)(96)(iii)(B)(6)(iii)
of Regulation S-K.

 FirstName LastNameKarl Hanneman
 Comapany NameInternational Tower Hill Mines Ltd.
 August 3, 2023 Page 4
 FirstName LastName
Karl Hanneman
International Tower Hill Mines Ltd.
August 3, 2023
Page 4
Section 10 - Mineral Processing and Metallurgical Testing
10.8 Opportunities for Further Investigation, page ES-10
8.The opinion of the qualified person on the adequacy of the data is required by Item
601(b)(96)(iii)(B)(10)(v) of Regulation S-K.
Section 12 - Mineral Reserve Estimates
12.3.3.6 Open Pit Design Results, page ES-12
9.The opinion of the qualified person on how the mineral reserve estimates could be
materially affected by risk factors associated with any aspect of the modifying factors or
changes therein is required by Item 601(b)(96)(iii)(B)(12)(vi) of Regulation S-K.
Section 17 - Environmental Studies, Permitting, and Plans, Negotiations, or Agreements with
Local Individuals or Groups, page ES-17
10.The opinion of the qualified person as to the adequacy of current plans to address any
issues related to environmental compliance, permitting, and local individuals or groups is
required by Item 601(b)(96)(iii)(B)(17)(vi) of Regulation S-K.

            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact George K. Schuler, Mining Engineer at (202) 551-3718 if you have
questions regarding comments on your mineral property information.  You may contact Jenifer
Gallagher, Staff Accountant at (202) 551-3706 or Karl Hiller, Branch Chief at (202) 551-3686 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation