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SEC Company Response from ENDEAVOUR SILVER CORP (EXK) (CIK 0001277866) (EXK) — Oct 10, 2008

ENDEAVOUR SILVER CORP (EXK) (CIK 0001277866)
Date: Oct. 10, 2008 · CIK: 0001277866 · Accession: 0000912282-08-001496

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File numbers found in text: 001-33153

Date
October 9, 2008
Author
/s/ Jason K. Brenkert
Form
CORRESP
Company
ENDEAVOUR SILVER CORP (EXK) (CIK 0001277866)

Letter

October 9, 2008

Via: EDGAR

Securities and Exchange Commission

Division of Corporate Finance

Mail Stop 7010

100 F Street, NE

Washington, D.C. 20549

Attention: Mr. John Lucas

Re:

Telephone conversation regarding

Endeavour Silver Corp.

Form 40-F for the Fiscal Year Ended December 31, 2007

Filed April 7, 2008

File No. 001-33153

Ladies and Gentlemen:

On behalf of our client, Endeavour Silver Corp. (the “Company”), I hereby respectfully submit this letter regarding my conversation with Mr. John Lucas on October 8, 2008 regarding the above-referenced Annual Report on Form 40-F for the fiscal year ended December 31, 2007, as filed with the Securities and Exchange Commission (“SEC”) on April 7, 2008 (File No. 001-33153).

The conversation was regarding the Company’s response to SEC staff comments on the Annual Report on Form 40-F provided to the Company on September 23, 2008. In a previous conversation with Mr. Lucas, I had indicated that the Company was anticipating filing an amended Annual Report on Form 40-F on October 3, 2008. However, as discussed with Mr. Lucas in our conversation on October 8, 2008, the Company’s auditors were still in the process of reviewing the amendments and the Company was waiting on their consent to file the amended Annual Report on Form 40-F.

I indicated in the conversation that the Company expects auditor approval on October 9, 2008 and the Company will promptly file the amended Annual Report on Form 40-F thereafter along with written correspondence responding to the staff’s comment letter.

If you should have any questions regarding the annual report or our response letter, please do not hesitate to contact me at 303-352-1133.

Sincerely,
/s/ Jason K. Brenkert

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CORRESP
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        October 9, 2008

                        Via: EDGAR

                        Securities and Exchange Commission

                        Division of Corporate Finance

                        Mail Stop 7010

                        100 F Street, NE

                        Washington, D.C. 20549

                        Attention: Mr. John Lucas

                        Re:

                        Telephone conversation regarding

        Endeavour Silver Corp.

        Form 40-F for the Fiscal Year Ended December 31, 2007

        Filed April 7, 2008

        File No. 001-33153

        Ladies and Gentlemen:

        On behalf of our client, Endeavour Silver Corp. (the “Company”), I hereby respectfully submit this letter regarding my conversation with Mr. John Lucas on October 8, 2008 regarding the above-referenced Annual Report on Form 40-F for the fiscal year ended December 31, 2007, as filed with the Securities and Exchange Commission (“SEC”) on April 7, 2008 (File No.
        001-33153).

        The conversation was regarding the Company’s response to SEC staff comments on the Annual Report on Form 40-F provided to the Company on September 23, 2008. In a previous conversation with Mr. Lucas, I had indicated that the Company was anticipating filing an amended Annual Report on Form 40-F on October 3, 2008. However, as discussed with Mr. Lucas in our conversation on October 8, 2008, the
        Company’s auditors were still in the process of reviewing the amendments and the Company was waiting on their consent to file the amended Annual Report on Form 40-F.

        I indicated in the conversation that the Company expects auditor approval on October 9, 2008 and the Company will promptly file the amended Annual Report on Form 40-F thereafter along with written correspondence responding to the staff’s comment letter.

        If you should have any questions regarding the annual report or our response letter, please do not hesitate to contact me at 303-352-1133.

        Sincerely,

        /s/ Jason K. Brenkert

        Jason K. Brenkert

        DORSEY & WHITNEY LLP