SecProbe.io

December 4, 2012

Via E -Mail
Bradford Cooke
Chief Executive Officer
Endeavour Silver Corp.
Suite 301 -700 West Pender Street
Vancouver, British Columbia
Canada  V6C 1G8

Re: Endeavour Silver Corp.
 Form 40-F for Fiscal Year Ended December 31, 2011
Filed April 2, 2012
File No. 001-33153

Dear Mr. Cooke :

We have reviewed your filing an d have the following comment.  In our comment , we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comment a pplies  to your facts and circumstances, please tell
us why in your response.

After reviewing the information you provide in response to this comment, we may have
additional comments.

Form 40 -F for Fiscal Year Ended December 31, 2011

Exhib it 99.2

Notes to the Consolidated Financial Statements

22. Transition to International Financial Accounting Standards

First time a doption of I FRS, page 30

1. We note that you do not address the mandatory exceptions, as set forth in paragraphs 14 -
17 and  Appendix B of IFRS 1 that you applied upon the adoption of IFRS. To the extent
that your financial statements reflect the use of mandatory exceptions, please identify for
us the items or class of items to which the exceptions were applied and describe the
accounting principle that was used and how it was applied.  In addition and to the extent

Bradford Cooke
Endeavour Silver Corp.
December 4, 2012
Page 2

 material, also qualitatively describe for us the impact on the financial condition, changes
in financial condition and results of operations that the treatment speci fied by IFRS
would have had absent these mandatory exceptions. Refer to paragraph 23 of IFRS 1.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information t he Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures  they have made.

 In responding to our comment, please provide  a written statement from the company
acknowledging 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 staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal secur ities laws of the United States.

You may contact  Blaise Rhodes, Staff Accountant  at (202) 551 -3774  or Angela Halac  at
(202) 551 -3398  if you h ave questions regarding our comment  on the financial statements and
related matters.

Sincerely,

/s/Tia L. Jenkins

Tia L. Jenkins
Senior Assistant Chief Accountant
Office of Beverages, Apparel , and
Mining