SecProbe.io

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November  4,  2005

MAIL  STOP  7010
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Mr.  H.  Roger  Schwall                                Faxed  to:  202-772-9368
Assistant  Director
U.S.  Securities  and  Exchange  Commission
450  Fifth  Street,  N.W.
Washington,  D.C.  20549

RE:     Battle  Mountain  Gold  Corp.  ("Registrant")
        Schedule  14C
        Filed  June  17,  2005
        Form  10-KSB
        Filed  April  22,  2005
        File  Number  0-50399

Dear  Mr.  Schwall:

In  response  to  your  comment  letter  of  September  30,  2005,  the  Company
respectfully  submits  the  following  responses  to  your  paragraph  number 4.

FORM  10-QSB-JUNE  30,  2005
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CONTROLS  AND  PROCEDURES
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4.  The  registrant hereby supplementally confirms that, as regards the comments
you  made  in  your July 12, 2005 letter relating to Form 10-KSB, the registrant
will provide information comparable to that requested in your comments numbers 8
and  9  in  all  future  filings,  and  as  to  comment number 7, the registrant
respectfully  submits  the  following  proposed  disclosure:

ITEM 8A.     CONTROLS AND PROCEDURES.

     (a)  Evaluation  of disclosure controls and procedures. The Company's chief
executive  officer  and  chief  financial  officer,  after  evaluating  the
effectiveness  of the Company's "disclosure controls and procedures" (as defined
in  the  Exchange Act Rules 13a-15(e) and 15d-15(e)) as of the end of the period
covered by this annual report (the "Evaluation Date"), have concluded that as of
the  Evaluation  Date, the Company's disclosure controls and procedures were (a)
not adequately designed to ensure that material information required to be
disclosed by the Company in the reports that it files or submits under the
Exchange Act of 1934  is  recorded,  processed, summarized and reported, within
the time periods specified  in the Commission's rules and forms, and (b) not
effective to ensure that the information was accumulated and communicated to the
Company's management to allow timely decisions regarding required disclosures.

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The material weakness, as observed by management in February and March 2005, was
that, in the opinion of management, the assignments and work were not being
completed by our accountants in a timely manner, such that the Company and its
auditor would have the financial data required in order to timely meet its
filing and reporting obligations under the Exchange Act. The Company believes
these problems began in the first quarter 2005. The Company's management
believes the delay in getting the necessary information and work product from
our accountant and auditor was due in large part to the fact that they were
located outside the U.S. and were foreign entities, and this seemed to cause
time delays in getting work completed. Our chief executive officer and chief
financial officer took immediate steps by obtaining a consulting accountant
(Wayne Richardson, CPA) and engaging another accounting firm (Mark Bailey and
Company) to prepare our  financial  statements  for  timely  audit  and review
by  our  principal independent accountant and to integrate the financial
accounting systems for the Company.  We also obtained a domestic local auditor,
Chisholm, Bierwolf and Nilson. Our chief executive officer and chief financial
officer believe  that  these  measures have improved our disclosure controls and
procedures and made them effective in regard to timely accumulation and
communication of financial information and data.

If you have any further questions or comments regarding these matters, please do
not  hesitate  to  contact  me.

Thank  you  again  for  your  kind  cooperation  and  assistance.

Very  truly  yours,

/s/  James  E.  McKay

James  E.  McKay,
President  and  CEO

cc:   Michael  J.  Morrison,  Esq.

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