SecProbe.io

CORRESP
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filename1.htm

    United
    States

    January
    12, 2024

    Securities
    and Exchange Commission

    Washington,
    DC 20549

    Division
    of Corporation Finance

    Office
    of Energy & Transportation

Re:
LIBERTY STAR URANIUM & METALS CORP.

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

Filed
May 16, 2023

File
No. 000-50071

Supplemental
to our Correspondence:

Posted
below is a redline of what was either moved to another area or changed in language by our QP. We added a more detailed map, and adjusted
terminology for identifying property altogether making it simpler language and clearer to the reader. We are prepared to file an Amended
10K at your request, however, we suggest that because none of our properties were material at the time of filing the original 10K, the
changes may be considered immaterial as an aggregate, and not require a 10K/A filing at this time. We will not rely on the RRC Technical
report and will not include it in filings moving forward due to the explanation we provided in the response letter. Of course, we rely
on your recommendation regarding what is needed currently, and we are prepared to file an Amended 10K if this seems necessary or more
appropriate in your opinion.

Page
3

Our
current business

We
are engaged in the acquisition and exploration of mineral properties in the state of Arizona inand
the Southwest USA. Claims in the state of Arizona are held in the name of Liberty Star. OurWe
use the term “Super Project” to indicate a project in which numerous mineral targets have been identified, any one or more
of which could potentially contain commercially viable quantities of minerals. Our significant projects are described
below.

Tombstone Area
Exploration Properties:Super Project (“Tombstone”):
Tombstone is located in Cochise County, Arizona and covers the Tombstone caldera and its environs. Within
the Tombstone caldera is the Hay Mountain,
target and Red Rock
Canyon target. All four of our exploration properties,
Hay Mountain, Red Rock Canyon, Tombstone and Robbers Roost lie within or on the flank of the Tombstone caldera structure. We
are concentrating our work at Red Rock Canyon at this time. We plan to ascertain whether the Tombstone,
Hay Mountain claims possess commercially viable deposits of copper, molybdenum, gold, silver, lead, zinc, manganese and
other metals including Rare Earth Elements (REE’s). We have not identified any ore reserves to date, although we have identified
mineralized areas which are materialmay
be of potential of economic
interest.

Title to mineral claims involves certain inherent
risks due to difficulties in determining the validity of certain claims, as well as potential for problems arising from the frequently
ambiguous conveyancing history characteristic of many mineral properties. We have investigated title to all the Company’s mineral
properties and, to the best of itsour
knowledge, title to all properties retained are in good standing.

The
mineral resource business generally consists of three stages: exploration, development and production. Mineral resource companies that
are in the exploration stage have not yet found mineral resources in commercially exploitable quantities and are engaged in exploring
land in an effort to discover them. Mineral resource companies that have located a mineral resource in commercially exploitable quantities
and are preparing to extract that resource are in the development stage, while those engaged in the extraction of a known mineral resource
are in the production stage. We have not found any mineral resources in commercially exploitable quantities.

    2

There is no assurance that a commercially
viable mineral deposit exists on any of our properties, and further exploration is required before we can evaluate whether any exist and,
if so, whether it would be economically feasible to develop or exploit those resources. Even if we complete our current exploration program
and we are successful in identifying a mineral deposit, we would be required to spend substantial funds on further drilling and engineering
studies before we could know whether that mineral deposit “material of economic interest”
will constitute a commercially viable mineral deposit one.,
known as an “ore reserve.”

Page
10

Tombstone:

Tombstone is a large and ancient (72 million years
before the present – or Laramide in age) volcanic structure – a caldera. The US Geological Survey caldera experts,
conclude this is correct. Subsequently, more than seventeen calderas of various ages have been identified in Arizona
by the US Geological survey, the Arizona Geological Survey and others. Such calderas of Laramide age are all associated with porphyry
alteration and copper and associated mineralization; many of these have become very large copper mines. Advanced technology has indicated
that alteration associated mineralization at Tombstone is much more extensive than originally thought. This alteration lies largely under
cover and is indicated by geochemistry, geophysics and projection of known geology into covered areas.

All the properties
summarized below are considered as “Exploration stage properties” under the definition of Item 1300 and are considered “non-material
properties.”

All State Mineral
Exploration Permits and Federal Lode Mining Claims held by the company are listed below.

The Hay
Mountain Project ©s located 6.5 miles southeast of Tombstone where we hold 35 Arizona State Mineral Exploration Permits (MEPs) covering
(12,878.18 acres) or 20.12 square miles, and 93 federal lode mining claims covering (1,594.68 acres) or 2.49 square miles and is accessible
by Hwy 80, Davis Rd. and Wild West Road.

LIBERTY
STAR

TOMBSTONE-AZ

Federal
Unpatented Claims

Claim
Names

HM
87-143

TS
168-176

Marco1A-Marco5E

Davis1A-DavisC

Claim
Acreage

57
HM Claims- 1095.18 acres

21
Marco Claims- 320 acres

6
Davis Claims- 80 acres

9
TS Claims- 99.5 acres

State
Exploration Permits

    MEP
    #

    Acres

    Renewal
    & Rental Due Date

    08-122642

    738.4

    11/24/2023

    08-122641

    375.64

    11/24/2023

    08-122640

    732.84

    11/24/2023

    08-123953

    480

    1/18/2024

    08-123952

    520

    1/18/2024

    08-119752

    40

    7/11/2023

    08-120017

    160

    6/15/2023

    08-120018

    80

    6/15/2023

    08-120172

    440

    10/4/2023

    08-120173

    640

    10/4/2023

    08-120174

    440

    10/4/2023

    08-120175

    480

    10/4/2023

    08-120176

    480

    10/4/2023

    08-120177

    582.83

    10/4/2023

    08-120178

    240

    10/4/2023

    08-120179

    370.24

    10/4/2023

    08-121131

    520

    11/18/2023

    08-121132

    368.76

    11/18/2023

    08-121133

    139.9

    11/18/2023

    08-121134

    280

    11/18/2023

    08-121135

    639.56

    11/18/2023

    08-121136

    600

    11/18/2023

    08-121137

    440

    11/18/2023

    08-121138

    358.85

    11/18/2023

    08-121139

    571.25

    11/18/2023

    08-121140

    439.5

    11/18/2023

    08-121141

    280

    11/18/2023

    08-121142

    640

    11/18/2023

    08-121143

    640

    11/18/2023

    08-121654

    80

    9/22/2023

    08-123795

    80.41

    11/15/2023

    08-121768

    449.44

    11/21/2022

    08-121769

    640

    11/21/2022

    08-121770

    626.32

    11/21/2022

    08-121771

    640

    11/21/2022

31State
MEP’s totaling

12,878.18
acres

    3

The Hay Mountain
Property is
 located 6.5 miles southeast of Tombstone where we hold 35 Arizona State Mineral Exploration
Permits (MEPs) covering (12,878.18 acres) or 20.12 square miles, and 93 federal lode mining claims covering (1,594.68 acres) or 2.49
square miles and is accessible by Hwy 80, Davis Rd. and Wild West Road.

At Hay Mountain, we plan to ascertain
whether the Hay Mountain lode mining claims and AZ MEPs possess commercially viable deposits of copper, gold, molybdenum, silver, zinc,
rare earth metals and other valuable metals. We have a phased exploration plan that involves diamond core
drilling of multiple holes over targets determined by analysis of geochemical sampling and ZTEM electromagnetic and magnetic
survey. Initial phase 1 drilling is planned to take approximately one year. Should results indicate the viability of the propertyproject,
additional phased work, both exploration and development, is planned over the course of seven total years to define the nature and size
of any potentialan ore bodiesbody(s)
and move toward mining. Any exploration plans are dependent on acquiring suitable funding. No part of the phased program is currently
funded.

    4

The Tombstone claims are undeveloped. However significant
amounts of aeromagnetic surveys, IP (Induced Polarization Surveys), geologic mapping by the USGS and others, and geochemical surveys including
soil, rock and vegetation sampling have been conducted at various times by various parties, over the last 60 years. When compiled and
analyzed these various data suggest a compelling series of anomalies that are typical of buried, dirt and rock covered porphyry copper
system(s). Below is a summary of prior exploration activities performed on our Tombstone claims: Technical Report: In mid-March
2011, Liberty Star contracted SRK to prepare three (3) Technical studies and Reports in a form similar to mineral reports prescribed under
NI 43-101. Members of SRK’s engineering/scientific staff supervised by a Qualified Person as defined under NI 43-101 and SRK’s
Tucson Office Principal Geologist, Corolla Hoag, and geologist Dr. Jan Rasmussen have visited the Tombstone property. This information
was combined with historic technical reports going back to 1878 and more recent data up to August 2011 (the date of their reports). The
three Technical Reports are entitled: (1) Walnut Creek Exploration Report, Tombstone District, Arizona –August 31, 2011, 147 pages;
(2) The Tombstone Caldera South Exploration Report, Tombstone District, Arizona –August 31, 2011, 144 pages; and (3) Hay Mountain
Exploration Report, Tombstone District, Arizona – August 31 2011, 155 pages. These reports covered the entirety of historic productive
area of the Tombstone mines which date to their discovery in 1877. However, before that report could be completed a competitor acquired
a lease on those lands. These Technical Reports thoroughly summarize and illustrate the salient geotechnical data of the Tombstone Mining
District covering about 250 square miles and present much data in computer map format. In such context, they analyze Liberty Star’s
exploration programs as related to the entire area, make estimates and recommend execution of proposed Company exploration programs.

Geochemical
sampling at the Hay Mountain PropertyProject:
In 2011 and early 2012 we collected nearly 1,800 rock, soil and vegetation samples over 621 sample sites over approximately 14 square
miles centered on the Hay Mountain property. These samples have been assayed for multiple elements generating many volumes of analyses.
The samples were prepared by MEG Inc. and have been shipped to ALS Global (f/k/a ALS-Chemex), geochemical
analysis lab in Vancouver, British Columbia. Assay results were sent to our Tucson office and all assays were received. Our
geology team has generated computer analyses that allow interpretation of the data. Liberty Star continues to collect
XRF readings and biogeochemical samples to further define the anomalies at Hay Mountain.

On June 15, 2020 we received
2 Mineral Exploration Permits (MEPs) issued by the Arizona State Land Department (ASLD) covering the 240-acre Robbers Roost exploration
area approximately 4.5 miles southwest of Tombstone, Arizona with access via paved road (Charleston Road). The new MEPs are 5.89 miles
west of Liberty Star’s Hay Mountain Project for porphyry copper, gold, and molybdenum. While the Robbers Roost MEP area is new
to the Company, it has been explored previously by several exploration companies, in the 1970’s and 1990’s, and recently
has received significant interest by others operating in the area. Drilling by ASARCO indicates “the presence of a granodioritic
porphyry intrusive at depth below the alteration zone. The intrusive is characterized by porphyry copper style alteration and mineralization.”
[JB Nelson, “Robbers’ Roost Summary Report,” 1995, p. 2 http://docs.azgs.az.gov/SpecColl/2008-01/2008-01-0103.pdf)

On June 24, 2020 we completed staking
an additional 400 acres of Federal Lode Claims contiguous to theat
Hay Mountain property. This addition to Liberty Star’s mineral claims effectively closes
all potential competitors’ opportunity to take a State or Federal mineral interest inside the Company’s contiguous State and
Federal mineral estate.

On November 11, 2020 we
announced the identification of potentially exploitable gold mineralization in its recently acquired State of Arizona Mineral Exploration
Permits (MEPs) land located in the area locally recognized as Red Rock Canyon, contiguous with and immediately north of drill Target
1, within the Company’s principal porphyry copper, gold, moly exploration target at the Hay Mountain Project (the “Project”)
previously disclosed. The relevant MEPs are in Township 20, Range 23 East, specifically eight sections 27 through 34 and two additional
MEPs, in sections 20 and 21. Preliminary surface exploration on the Red Rock MEPs advances the Company’s knowledge of the porphyry
system signature associated with magnetic highs at, and adjacent to the north of, Target 1, and represent the expansion of biogeochemical,
surface rock sampling, and x-ray fluorescence (XRF) work continuing at Target 1 and on the anticipated gold halo likely associated with
the indicated porphyry center.

On
October 21, 2019,On November
21, 2020 we acquired 5 new Mineral Exploration Permits for a total of 2,995.47 acres. Liberty Star’s CEO Brett Gross notes the
new applications complement last year’s land acquisition announced October 21, 2019 (Update 910);
“In 2019 we moved to secure surface access to support future development and operations. With the addition of these lands,
the Company secures three additional access routes from public roadways. While over the past twenty-two months we have enjoyed increasingly
good, collaborative and cooperative relations with the private property owners contiguous to the Hay Mountain Project with no interruptions
to project access, securing multiple alternative routes places us in an even more secure and well-defined position for the future.”

On
October 21, 2019 we acquired 13 new Mineral
Exploration Permits (MEP’s) for a total of 5,917.82 acres, or 9.25 sq miles bringing our total MEPs at Hay Mountain to 28 and 12,557.77
acres or 19.62 sq miles. This new acquisition represents a nearly 89% increase in Liberty Star lands under permit for mineral exploration
activities. These acquisitions not only substantially expand Liberty Star’s continued exploration potential, but also provide resistance
to existing competitive pressures. that permits us to be more
forthcoming with our technical data sharing with potential venture partners. Liberty Star geochemical and geophysical
surface studies indicate anomalies consistent with a large, buried porphyry copper body at the primary target,
and potentially extensive associated porphyry cluster, with attendant metals including gold, molybdenummoly,
nickel, silver, zinc, lead, and cobalt. See news release: https://www.libertystaruranium.com/2019/10/21/liberty-star-adds-over-9-square-miles-to-the-hay-mountain-
property.project/.

In 2019 Liberty Star contracted Pim van Geffen, PhD, PGeo of Vancouver
Geochemistry to provide services in the form of validation and interpretation of our biogeochemical data from the Hay Mountain Property.Project,
Tombstone District, Arizona. In particular, the quality of the biogeochemical data was assessed regarding its capacit