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 6900 E Layton Ave

                                                                                Suite 700

                                                                                Denver, CO 80237

 P   303.863,7414

                                                                                F   303.837.5837

                                                                                newmont.com

June 13, 2024

VIA EDGAR

Sondra Snyder

Gus Rodriguez

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

100 F Street, NE,

Washington, DC 20549

 Re: Newmont Corporation

Form 10-K for Fiscal Year Ended December 31, 2023

Filed February 29, 2024

Response dated June 13, 2024 (the “Response”)

File No. 001-31240

Dear Ms. Snyder and Mr. Rodriquez

Please find below the response of Newmont Corporation, a Delaware corporation
(“Newmont,” the “Company,” “our” and “we”) to the comment of the staff (the “Staff”)
of the U.S. Securities and Exchange Commission (the “Commission”) that was contained in the Staff’s letter to Mr. Peter
Wexler, Executive Vice President and Chief Legal Officer, of the Company dated May 22, 2024 (the “Comment Letter”).

For ease of reference, the comment contained in the Comment Letter
is reprinted below in bold and is followed by the Company’s response.

Form 10-K for the Fiscal Year Ended December 31, 2023

Financial Statements

Note 7 – Impairment Charges, page 160

 1. We note that your cumulative losses before income and mining tax and other items for the Yanacocha segment over the last three
years amount to $3.2 billion; and that annual losses exceeded revenues for the segment in each of the three years.

Given the consecutive operating
losses and $2.1 billion in total assets reported for the Yanacocha segment, please explain to us how you assessed the long-lived assets
of the segment for recoverability in determining there was no impairment in 2023 or 2022, and in booking the $1 million impairment in
2021.

Please submit the analysis that
you performed in making these determinations, including details of all key assumptions involved and the basis for those assumptions.

The
Company acknowledges the Staff’s comment and advises the Staff that the Company reviews and evaluates its long-lived assets for
impairment when events or circumstances indicate that the related carrying value may not be recoverable. The estimated undiscounted cashflows
used to assess recoverability of long-lived assets are derived from current business plans, which are developed using short-term price
forecasts reflective of the current price environment and management’s projections of long-term average metal prices. In
addition to short- and long-term metal price assumptions, other assumptions include estimates of commodity-based and other input costs;
proven and probable mineral reserve estimates, including the timing and cost to develop and produce the reserves; and value beyond proven
and probable mineral reserve estimates.

In
accordance with FASB Accounting Standards Codification 360 (“ASC 360”), the Company tested the long-lived assets of the Yanacocha
segment for recoverability during the years ended December 31, 2023 and 2022 and concluded there was no impairment. The recoverability
tests in both years included undiscounted cashflows from the Yanacocha segment consisting of current operations and the Yanacocha
Sulfides development project, which is material to the future cashflows of the Yanacocha segment. The Yanacocha segment excludes the Conga
development project, also in Peru, which is reported in Note 4, Segment Information, within ‘Corporate and Other’ of
the Form 10-K for the fiscal years ended December 31, 2023. Additional details relating
to the Yanacocha Sulfides development project are discussed under the heading ‘Yanacocha Sulfides Project’ below.

Historical Operating Losses at the Yanacocha
Segment

The Company acknowledges that cumulative losses before income and mining
tax and other items for the Yanacocha segment over the last three years amounted to $3.2 billion, and that annual losses exceeded revenues
for the reporting unit in each of the three years ended December 31, 2023. These cumulative losses resulted from reclamation adjustments
recognized by the Company for the portions of the Yanacocha site that are no longer in production and have no expected substantive economic
value (i.e., non-operating), and were unrelated to Yanacocha’s long-lived asset group representing current operations and the Yanacocha
Sulfides development project. The Company’s disclosure in Note 6, Reclamation and Remediation, of the Form 10-K for the fiscal
year ended December 31, 2023 reads as follows:

In 2023, reclamation adjustments were primarily due to
increased water management costs at portions of the Yanacocha site that are no longer in production and with no expected substantive economic
value (i.e., non-operating), that resulted in an increase of $1,101. In 2022, reclamation adjustments were primarily due to higher estimated
closure costs resulting from cost inflation and increased water management costs at portions of the Yanacocha and Porcupine site operations
that are non-operating that resulted in increases of $529 and $91, respectively. In 2021, reclamation adjustments were primarily comprised
of $1,554 related to non-operating portions of the Yanacocha site.

Because the future cash outflows associated with the reclamation adjustments
at the non-operating portions of the Yanacocha site are not related to the future recoverability of the long-lived assets, these future
cash outflows are not included in the recoverability model, discussed further under the heading ‘Recoverability Assessment and Conclusions’.

Yanacocha Sulfides Project

At December 31, 2023, the Company reported $2,117 million of total
assets at the Yanacocha segment, which included the long-lived assets of the Yanacocha segment, cash balances and various other assets.
As of December 31, 2023 and 2022, the Yanacocha long-lived asset group had carrying values of $1,474 and $1,208 million, respectively,
which included $911 and $621 million of assets under construction related to the Yanacocha Sulfides development project, respectively.
The first phase of the Yanacocha Sulfides development project will extend the Yanacocha segment’s operations beyond 2040. This includes
the development of the first phase of sulfide deposits and an integrated processing circuit. A second and third phase, which would include
developing resources and exploration potential beyond the proven and probable reserves, would extend the life-of-mine (“LOM”)
for several additional decades.

In the third quarter of 2022, the Company announced the first delay
of the full-funds investment decision relating to the Yanacocha Sulfides development project to the second half of 2024. In the second
quarter of 2023, the Company announced a further delay in the full-funds investment decision for at least two years to the second half
of 2026. These decisions were in response to challenging market conditions and the proposed acquisition of Newcrest (subsequently closed
on November 6, 2023). The delay allows the Company to advance its portfolio optimization strategy, which is designed to maximize
returns for shareholders, prioritize and sequence the development of the most value-accretive opportunities across the combined portfolio,
and to support the Company’s disciplined capital allocation strategy. The Company continued to advance engineering and long-term
procurement activities to maximize the Yanacocha Sulfides development project economics and prepare for a future full-funds investment
decision.

Recoverability Assessments and Conclusions

Management evaluated the delay of the Yanacocha Sulfides development
project full-funds investment decision as a potential impairment indicator during both of the years ended December 31, 2023 and 2022,
and tested the long-lived asset group for recoverability in accordance with ASC 360. The estimated undiscounted cashflows used to assess
recoverability of long-lived assets were derived from current business plans, which included current operations and the future development
and operation of the Yanacocha Sulfides development project. The estimated undiscounted cashflows related to this project were based on
a 70 percent development case probability factor, reflecting the uncertainty related to the pending full-funds investment decision. The
development case probability factor was developed from discussions with executive leadership at the time of the assessment and supported
by continued development capital spending of approximately $290 million and $405 million in 2023 and 2022, respectively.

In addition to the assumed development and operation of the Yanacocha
Sulfides development project and applied probability factor, the undiscounted cashflows included the following key assumptions:

    Key
    Assumptions
    FY
    2022 Assessment
    FY
    2023 Assessment

    Contained
    Metal Mined

    Contained
    gold mined 1
    5.9
    million ounces
    5.6
    million ounces

    Contained
    copper mined 2
    1,570
    million pounds
    1,570
    million pounds

    LOM
    20
    years (2023-2042)
    21
    years (2024-2044)

    Metal
    Pricing

    Long-term
    gold 3
    $1,600
    per ounce
    $1,600
    per ounce

    Long-term
    copper 3
    $3.50
    per pound
    $3.50
    per pound

    Yanacocha
    Sulfides Development Project

    Development
    capital
    $3.2
    billion
    $2.8
    billion

    Operating
    costs per gold equivalent ounce (“GEO”)
    $700
    per GEO
    $700
    per GEO

    Commercial
    production
    2028
    2030

1
Contained gold mined of 5.9 and 5.6 million ounces corresponds to declared proven and probable
reserves of 5.8 and 5.5 million ounces in Item 2. Properties of the Form 10-K for the fiscal years ended December 31,
2022 and December 31, 2023, respectively.

2
Contained copper mined of 1,570 and 1,570 million pounds corresponds to declared proven and
probable reserves of 1,530 and 1,500 million pounds in Item 2. Properties of the Form 10-K for the fiscal years ended December 31,
2022 and December 31, 2023, respectively.

3
The Company’s long-term gold and copper metal price assumptions are derived and supported
by analyst consensus pricing.

In both assessments, the initial undiscounted cashflows exceeded the
carrying value of the Yanacocha segment long-lived asset group by more than $500 million or approximately 40 percent of the carrying value
of the long-lived asset group. The probability factor applied to the Yanacocha Sulfides development project cash flows would need to fall
below 50 percent before the carrying value would exceed the undiscounted LOM cashflows. The undiscounted LOM cashflows used in the recoverability
assessment did not include incremental cashflows relating to resources and exploration potential (the potential second and third phases
of the Yanacocha Sulfides development project), which, if included, would further increase the excess of undiscounted cashflows over the
long-lived asset group’s carrying value. The significance of the Yanacocha Sulfides development project to the Yanacocha segment
is highlighted in Note 2, Summary of Significant Accounting Policies, of the Form 10-K for the fiscal years ended December 31,
2023 and 2022:

“Should
the Company ultimately decide to forgo the development of Yanacocha Sulfides, the current carrying value of the assets under
construction and other long-lived assets of the Yanacocha operations could become impaired and the timing of certain closure
activities would be accelerated.”

The $1 million impairment recorded at the Yanacocha segment for the
year ended December 31, 2021 related to a write-down of materials and supplies inventory, based on an assessment that certain inventory
parts would no longer be used in the operation.

******

In connection with responding to the Staff’s comments, the Company
is aware of and acknowledges 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 the Staff’s comments as a defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.

If the Staff wishes to discuss the responses provided above at any
time, please do not hesitate to contact me.

    Sincerely,

    /s/ Karyn Ovelmen

    Karyn Ovelmen

    Executive Vice President and Chief Financial Officer

cc:          Sondra
Snyder, Senior Staff Accountant, Division of Corporation Finance

Gus Rodriguez, Branch Chief - Energy, Financial Services
and Life Sciences Groups, Division of Corporation Finance

Peter Wexler, Executive Vice President and Chief
Legal Officer

Joshua Cage, Vice President, Controller and Chief
Accounting Officer

Logan Hennessey, Vice President, Deputy General
Counsel and Corporate Secretary

David Johansen, Partner, White & Case
LLP

Andrea Lovelady, Partner, Ernst & Young
LLP

Grant Nelson, Partner, Ernst & Young LLP