SecProbe.io

CORRESP
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filename1.htm

April
6, 2020

Office
of Energy & Transportation

Division
of Corporation Finance

Attn:
Irene Barberena-Meissner

U.S.
Securities and Exchange Commission

Washington,
D.C. 20549

    Re:
    Desert
    Hawk Gold Corp.

    Registration
    Statement on Form S-1

    Filed February
    12, 2020

    File
    No. 333-236398

Dear
Ms. Barberena-Meissner:

In
connection with your comment letter dated February 25, 2020, to the registration statement on Form S-1 (the “Registration
Statement”) of Desert Hawk Gold Corp. (the “Company”), I have been authorized to provide you with the following
responses to the comments contained in your letter:

General

 1. Based
                                         on the filing date of this registration statement, it appears your effective date could
                                         be after 45 days but within 90 days of your fiscal year end. As it appears you may not
                                         satisfy the conditions of Item 8-08(b) of Regulation S-X, please file your audited financial
                                         statements for the fiscal year ended December 31, 2019, prior to the requested date of
                                         effectiveness of your registration statement, or provide your analysis of why you believe
                                         you are not required to update your financial statements. For additional guidance, please
                                         consider Section 1220.3 of the Division's Financial Reporting Manual.

RESPONSE:
On March 30, 2020, the Company filed its 2019 annual report on Form 10-K, which included audited financial statements for
the years ended December 31, 2019 and 2018. The financial statements filed with this annual report have been included in the amendment
to the registration statement filed by the Company this day.

Irene
Barberena-Meissner

April
6, 2020

Page
2

The
amended Form S-1 includes the 2019 financial statements and the MD&A section from the Company’s 2019 10-K report. In
addition, there are some minor updates to the document.

 ● The
                                         number of shares owned by Clifton Mining, the selling stockholder, has been corrected
                                         on pages 9 of the prospectus.

 ● Some
                                         minor changes and updates have been included in the Business and Properties sections
                                         of the prospectus.

 ● Information
                                         under the subheading Certain Relationships and Related Transactions within the
                                         Management section of the prospectus has been updated.

 ● A
                                         risk factor has been added addressing the coronavirus pandemic.

Finally,
we have included an updated legal opinion and the auditor’s consent as exhibits to this filing.

The
Company intends to request a date of effectiveness for the filing as soon as you have had an opportunity to review the revised
document. Once you have reviewed this filing, I would like to coordinate with you the request for effectiveness. I am working
from home, but my direct office number (801.988.5862) is forwarded to my cell phone. I also have access to email and all of my
files from my laptop.

Please
feel free to contact me if further information is required.

    Sincerely,

    /s/
    Ronald N. Vance

    cc:
    Rick
    Havenstrite, CEO

    Marianne
    Havenstrite, Principal Financial Officer

    Delaine Gruber,
    DeCoria, Maichel & Teague, P.S.