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 March 10, 2025

Joseph Mullin
Chief Executive Officer
Rise Gold Corp.
650 - 669 Howe Street
Vancouver, British Columbia, Canada V6C 0B4

 Re: Rise Gold Corp.
 Form 10-K for the Fiscal Year ended July 31, 2024
 Filed October 29, 2024
 Response dated March 3, 2025
 File No. 000-53848
Dear Joseph Mullin:

 We have reviewed your March 3, 2025 response to our comment letter and
have the
following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our February
4, 2025 letter.

Form 10-K for the Fiscal Year ended July 31, 2024
Financial Statements
Note 6 - Mineral Property Interests, page 65

1. We understand from your response to prior comment one that you did not
test the
 capitalized mine costs for recoverability even though you have a history
of losses and
 negative operating cash flows, because you did not consider this to be
unusual for a
 junior mining exploration company that is evaluating mining projects.

 However, these are circumstances under which you must periodically test
the
 capitalized mine costs for recoverability, notwithstanding your status
as a junior
 mining exploration company, given the example in FASB ASC
360-10-35-21(e). The
 denial of your mining use permit application by the immediate governing
authority is
 March 10, 2025
Page 2

 also an event that would require you to test the capitalized mine costs
for
 recoverability, given the example in FASB ASC 360-10-35-21(c).

 As each of these matters would independently require a test for
impairment, please
 conduct the required test and discuss your findings with the auditor,
including any
 implications for the financial statements, related disclosures, and the
audit opinion,
 which presently includes a reference to this topic. Provide us with the
impairment test
 that you perform as of July 31, 2024, based on information that was
available prior to
 filing your annual report on October 29, 2024. We reissue prior comment
one.

2. We note your response to prior comment five, concerning your potential
 taking claim, stating the company "...has not claimed and does not claim
that the mine
 is currently worth $400 million," although in your November 27, 2024 and
January
 16, 2025 press releases, you state "The remedy for an unconstitutional
taking is the
 payment of just compensation, which is the fair market value of the
property taken.
 Based on comparable mines and historic yields at the I-M Mine, management
believes
 the fair market value of Rise's mineral estate is at least $400 million."

 We believe that you must have a reasonable basis for disclosures that
investors would
 reasonably regard as indicative of a potential recovery in value for
damages incurred.
 As such, we believe that you should further revise disclosures in the
current reports on
 Form 8-K that were utilized as a vehicle for this information to clarify
the nature and
 extent of any support for the potential claim amount.

 For example, describe the population of mines that you believe are
comparable, the
 means of determining comparability and value; and the salient historic
yield
 parameters that were utilized and explain why you believe these are both
relevant and
 appropriate, considering the exploration status of a property for which
you have
 reported neither resources nor proved reserves.

 However, if you are unable to show a reasonable basis for the amount of
your
 potential taking claim, provide clarifying disclosure that clearly
conveys the extent of
 conjecture that was involved in quantifying the claim amount, and to
caution investors
 about placing reliance on the estimate. Under these circumstances, also
expand the
 risk factor disclosures in subsequent periodic reports to similarly
caution investors on
 any potential recovery if this strategy is pursued, and refrain from
quantifying
 damages or claims for which you are unable to show a reasonable basis.

 If you believe that you have a reasonable basis for the disclosure that
was made,
 provide us with the support, to include details of the comparable
properties,
 descriptions of the characteristics and corresponding valuations, the
historic yields
 from your property, timeframes in which the related production occurred,
along with
 the volumes, prices, and costs; and describe the assumptions involved in
calculating
 the potential taking claim amount. We reissue prior comment five.
 March 10, 2025
Page 3

 Please contact Robert Babula at 202-551-3339 or Karl Hiller at
202-551-3686 if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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