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INCEPTION
MINING INC.

5330
South 900 East, Suite 280

Murray,
Utah 84117

November
10, 2016

Via
Edgar

Securities
and Exchange Commission

Division
of Corporation Finance

100
F Street N.E.

Mail
Stop 3561

Washington
DC 20549

Attn:
John Reynolds, Assistant Director

    Re:
    Inception
    Mining Inc.

    Form
    10-K for the Fiscal Year Ended December 31, 2015

    Filed
    May 3, 2016

    File
    No. 000-55219

Dear
Mr. Reynolds:

We
have received your letter dated October 17, 2016 regarding the Company’s Annual Report on Form 10-K and have prepared the
following responses to your comments. Supplemental information requested is provided in the included Exhibit A, where applicable,
with the proposed additions in red text.

Form
8-K filed July 27, 2016

Exhibit
99.1

1.
We note your reference to a 43-101 technical analysis report in your press release furnished to the Commission on July 27, 2016.
Please forward to our engineer, as supplemental information and not as part of your filing, the referenced technical report pursuant
to paragraph (c) of Industry Guide 7. Please provide this information on a CD, formatted as Adobe PDF files. You may ask to have
this information returned by making a written request at the time it is furnished, as provide in Rule 12b-4 of Regulation 12B.
If you have questions concerning the above request, please contact John Coleman, Mining Engineer at (202) 551-3610.

RESPONSE:
The requested supplemental information is being delivered to you separately on a CD.

Form
10-K for the Fiscal Year Ended December 31, 2015

Item
2. Properties

2.
In future filings please include a map showing the location and access to each of your material properties pursuant to paragraph
(b)(2) of Industry Guide 7. Please include a draft of your proposed future disclosure with your response.

RESPONSE:
Maps of the UP & Burlington claim and Clavo Rico concession have been included in proposed future disclosure provided herewith
as Exhibit A to show the items requested.

3.
In future filings please disclose the information regarding your land and mineral rights for each of your material properties
pursuant to paragraph (b)(2) of Industry Guide 7. If you have identified properties in your filing that are not material, include
a statement to that effect in your disclosure and clarify your intentions. For each material property include the following information:

    ●
    A
    description of all interests in your properties, including the material terms of all underlying agreements and royalties.

    ●
    Please
    include certain identifying information, such as the property names, claim numbers, grant numbers, mining concession name
    or number, and dates of recording and expiration such that your claims may be distinguished from other claims that may exist
    in the area of your properties.

    ●
    The
    conditions that must be met to retain your rights, claims or leases, including the quantification and timing of all necessary
    payments.

Please
include a draft of your proposed future disclosure with your response.

RESPONSE:
We have included a draft of our proposed future filings as Exhibit A to this letter. Regarding Clavo Rico, the Company acquired
the land known as the Modesto property pursuant to a real estate purchase agreement in December 2015, and accordingly controls
that parcel outright (in addition to the main Clavo Rico parcel). The Company has informal arrangements with the owners of the
Loli and Juan Carlos Williams properties to explore those lands. Production at this mine is subject to a 5% net smelter royalty
and a 3% refinery royalty.

Regarding
UP & Burlington, the Company acquired the real property where the mine is located on February 25, 2013, accompanied by the
necessary exploration and mineral rights permits needed to explore and carry out mining activities thereon. Accordingly, the Company
owns and controls this property exclusively and there are no conditions to be met to satisfy any lease or license agreement. However,
in connection with the acquisition of this mine, production at this mine is subject to a 3% net smelter royalty. This royalty
may increase or decrease depending on the amount of gold produced.

The
Company has ceased all exploration in the State of Nevada.

4.
Revise future filings to clarify if your Clavo Rico Gold Mine is a surface or underground operation. Please include a draft of
your proposed future disclosure with your response.

RESPONSE:
Clavo Rico is a surface mining operation; we have included that fact in our proposed future filings language included here as
Exhibit A.

5.
We note that you are extracting material from your Clavo Rico Gold Mine in Honduras. In future filings include extraction information
including tons extracted, grade of material extracted, processing recoveries, and ounces produced and sold. Please include a draft
of you proposed future disclosure with your response.

RESPONSE:
We have included our proposed future filings language as Exhibit A to this letter for your review and comment. The current recovery
operation has been sized to handle from 500 to 1,000 tons of extracted material per day on a recovery bed that has the capacity
to receive up to 500,000 tons of material. The Company commenced full operations on January 1, 2012 and believes that sufficiently
high gold content ore bodies have been located and blocked out to load the recovery bed to capacity by the end of 2017. The Company
has engaged in preliminary drilling of this area and the resulting assays of samples indicate that the ore should have grades
in the range of 0-5 grams of gold per ton.

During
the period covered under this Annual/Quarterly Report, the Company extracted __ tons of material, with an average grade of __
parts per ton. After processing this material using the on-site leach pad, the Company produced __ ounces of gold/copper for assaying
and refining, for a recovery percentage of __%.

6.
Please tell us if you have other exploration properties and revise future filings to include a summary of these properties. Please
include a draft of your proposed future disclosure with your response.

RESPONSE:
Except as disclosed herein or in other of the Company’s filings with the Commission, the Company does not explore or use
any other properties. We have included that disclosure in our proposed future filings language included as Exhibit A to this letter.

Item
7. Management’s Discussion and Analysis of Financial Conditions and Results of Operations

7.
We note your use of the term ore on page 22 when describing mineralization at your Clavo Rico Gold Mine. Pursuant to paragraph
(a)(1) of Industry Guide 7 the term ore is commensurate with the term reserve. In future filings, please revise to remove this
term until you have established proven or provable reserves.

RESPONSE:
The term “ore” as used in this section has been replaced with language that accurately portrays the processes described
therein, yet does not infringe on pre-defined terms.

The
Company 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 staff comments as a defense in any proceeding initiated by the Commission or any person under the federal
    securities laws of the United States.

Sincerely,

    Inception
    Mining Inc.

    /s/
    Michael Ahlin

    Chief
    Executive Officer

EXHIBIT
A

Proposed
Language to be Used in Future Filings

PROPERTIES
– Part I, Item 2 of Form 10-K

UP
& Burlington Gold Mine, Salmon, Lemhi County, Idaho

On
February 25, 2013, the Company acquired certain real property and mineral rights commonly known as the UP and Burlington Gold
Mine (“UP & Burlington”) pursuant to an asset purchase agreement. We are presently in the exploration stage at
UP & Burlington. The UP & Burlington project consists of two federal patented mining claims, which Inception Resources
Mining acquired for the purpose of the exploration and potential development of gold on the 40 acres that comprise this property.

Discovered
in 1892, UP & Burlington is a private gold property that has been held unused for the past 75 years. UP & Burlington is
located in Lemhi County, northwest of Salmon, Idaho, at an elevation of 3,994 feet. The UP & Burlington site is located six
miles from the city of Salmon; 0.6 miles from the closest major road (Ridge Rd.); and 1.56 miles from the closest major power
line. We believe Salmon, along with the surrounding County of Lemhi, provides an excellent infrastructure for our mine. Salmon
has a population of 3,122 and Lemhi County has a population of 7,806.

UP
& Burlington’s two gold mining claims were brought to patent in 1900, which covers the Mine’s 40 acres. Subsequently,
in 1989, a U.S. Forest Survey was performed on the UP & Burlington site confirming that the patented claims cover an area
that is six hundred feet by three thousand feet (600’ x 3000’). The Mine’s patented claims remove the challenges
associated when working on U.S. Forest lands, Bureau of Land Management (“BLM”), state or other property types. With
our purchase of UP & Burlington, we have the benefit of working on private land, which requires only a hauling/road permit
to commence significant operations.

The
Company has obtained the necessary permitting, cut additional access roads, made surface improvements, and initiated surface mining
on a 2,500 foot per day lighted vein for bulk sampling, vein definition and material evaluation. In Phase II, we plan to contract
with an underground mining contractor to expand portal development leveraging existing underground access, and implement an underground
mining operation. There is no guarantee that we will be successful in implementing any stage of our plans.

Our
plan includes the continuation of obtaining a Lemhi County Conditional Use Permit and an Idaho Department of Lands Surface Reclamation
Bond. Since receiving the permitting for the U.S. Forest Service Access Road, the access road is now complete. In addition, we
have contracts such as geotechnical contracts, mining contracts, toll processing contracts, and underground mine plan contracts.

Clavo
Rico Gold Mine, Honduras, Central America

On
October 2, 2015, the Company consummated a merger with Clavo Rico Ltd. (“Clavo Rico”). Clavo Rico is a privately held
Turks and Caicos company with principal operations in Honduras, Central America. Clavo Rico operates the Clavo Rico mining concession
through its subsidiary Compañía Minera Cerros del Sur, S.A de C.V. Its workings include several historical underground
mining operations dating back to the early Mayan and Spanish occupation.

The
Company’s primary mine is a surface operation, located on the 200-hectare Clavo Rico Concession, located in southern Honduras.
This mine was originally explored and exploited in the 16th century by the Spanish, and more recently has been operated by Compañía
Minera Cerros del Sur, S.A. de R.L. as a small family business. In 2003, Clavo Rico’s predecessor purchased a 20% interest
and later increased its ownership to 99.5%. This company has since invested over five million dollars in the expansion and development
of the mine and surrounding properties. Today, the Company operates this mine through exploration of surface-level material.

The
current recovery operation has been sized to handle from 500 to 1,000 tons of extracted material per day on a recovery bed that
has the capacity to receive up to 500,000 tons of material. The Company commenced full operations on January 1, 2012 and believes
that sufficiently high gold content ore bodies have been located and blocked out to load the recovery bed to capacity by the end
of 2017. The Company has engaged in preliminary drilling and the resulting assays of samples indicate that the material should
have grades in the range of 0-5 grams of gold per ton.

During
the period covered under this Annual/Quarterly Report, the Company extracted __ tons of material through surface operations, with
an average grade of __ grams of gold per ton and __ grams of silver per ton. After processing this material using the on-site
leach pad, the Company produced __ ounces of gold and __ ounces of silver for refining, for a recovery percentage of __%.

The
Company utilizes four distinct properties located at the Clavo Rico Concession: the main Clavo Rico property, where extraction,
leaching, and processing occurs, and the Modesto, Loli, and Juan Carlos Williams properties, which are used as extraction sites.
The Modesto location was acquired by the Company pursuant to a real estate purchase agreement in December 2015. The Company is
permitted access to the Loli and Juan Carlos Williams properties pursuant to informal oral agreements.

The
Clavo Rico Concession in relation to the town of El Corpus.

Parcels
of the Clavo Rico Concession that are currently explored or otherwise used by the Company.

The
Company had previously disclosed exploration in the Northern Nevada Rift through a partner. Any exploration in these areas has
ceased and the Company has no plans to pursue exploration in this area at this time.

Corporate
Headquarters

We
currently maintain our corporate offices at 5330 South 900 East, Suite 280, Murray, Utah 84117. During the year ending ___, we
paid monthly rent of approximately $1,000 for use of a corporate office, which we anticipate will be sufficient until we commence
full operations.

MANAGEMENT’S
DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATIONS – Part II, Item 7 in Form 10-K; Part I, Item 2
in Form 10-Q

Forward
Looking Statements

Except
for historical information, the following Management’s Discussion and Analysis contains forward-looking statements based
upon current expectations that involve certain risks and uncertainties. Such forward-looking statements include statements regarding,
among other things, (a) discussions about mineral resources and mineralized material, (b) our projected sales and profitability,
(c) our growth strategies, (d) anticipated trends in our industry, (e) our future financing plans, (f) our anticipated needs for
working capital, (g) our lack of operational experience and (h) the benefits related to ownership of our common stock. Forward-looking
statements, which involve assumptions and describe our future plans, strategies, and expectations, are generally identifiable
by use of the words “may,” “will,” “should,” “expect,” “anticipate,”
“estimate,” “believe,” “intend,” or “project” or the negative of these words or
other variations on these words or comparable terminology. This information may involve known and unknown risks, uncertainties,
and other factors that may cause our actual results, performance, or achievements to be materially different from the future results,
performance, or achievements expressed or implied by any forward-looking statements. These statements may be found under “Management’s
Discussion and Analysis of Financial Condition and Results of Operations” and “Description of Business,” as
well as in this Report generally. Actual events or results may differ materially from those discussed in forward-looking statements
as a result of various factors, including, without limitation, the risks outlined under “Risk Factors” and matters
described in this Report generally. In light of these risks and uncertainties, there can be no assurance that the forward-looking
statements contained in this Report will in fact occur as projected.

Overview

On
February 25, 2013, Inception Mining, Inc. (“Inception” or the “Company”) and its majority shareholder
(the “Majority Shareholder”), and its wholly-owned subsidiary, Inception Development Inc. (the “Subsidi