SecProbe.io

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								March 22, 2005

Mail Stop 0511

Mr. Robert N. Martin
President
Daybreak Mines, Inc.
805 Mullan Avenue
P.O. Box 370
Osburn, ID   83849

Re:	Daybreak Mines, Inc.
	Form 8-K/A#1 filed February 24, 2005
	File No. 0-50107

Dear  Mr. Martin:

      We have reviewed your filing and have the following comment.
Where indicated, we think you should revise your document in
response
to this comment.  If you disagree, we will consider your
explanation
as to why our comment is inapplicable or a revision is
unnecessary.
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 comment or any other aspect
of
our review.  Feel free to call the applicable staff person at the
telephone number listed at the end of this letter.

Item 4.01 - Changes in Registrant`s Certifying Accountant

1.	Please obtain and file an updated Exhibit 16 letter from the
former accountants stating whether the accountants agree with your
item 304 disclosures, or to the extent to which the accountants do
not agree.

      Please file your supplemental response and amendment via
EDGAR
in response to this comment within 5 business days after the date
of
this letter.  Please contact the staff immediately if you require
longer than 5 business days to respond.

      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 registrant and its management are
in
possession of all facts relating to a registrant`s disclosure,
they
are responsible for the accuracy and adequacy of the disclosures
they
have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the registrant acknowledging that:
* the registrant 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 registrant 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.

      Direct any questions regarding this letter to me at
202.942.1808.

						Sincerely,

						David Burton
						Staff Accountant
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0306

         DIVISION OF
CORPORATION FINANCE

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