SecProbe.io

CORRESP
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    Daniel M. Miller

    Partner

    (604) 630-5199

    FAX (604) 687-8504

    miller.dan@dorsey.com

August 11, 2025

    Division of Corporation Finance

    Office of Energy & Transportation

    Securities and Exchange Commission

    100 F Street N.E.

    Washington, D.C. 20549

    Re:
    Alaska Silver Corp.
 Draft Registration Statement on Form S-1
 Submitted May 14, 2025
 CIK No. 0001893899

Dear Sirs and Mesdames:

On behalf of our client, Alaska Silver Corp. (the “Company ”),
and pursuant to the Securities Act of 1933, as amended, and the rules and regulations thereunder, we transmit for your review the
Company’s responses to the Staff’s letter of comments, dated June 10, 2025 (the “Comment Letter”), in respect
of the above noted submission (the “Draft Registration Statement”). The Company’s responses below are keyed to the headings
and comment numbers contained in the Comment Letter. In connection with this letter, Amendment No. 1 to the Draft Registration Statement
(the “DRS Amendment No. 1”) is being filed concurrently herewith. All capitalized terms used and not otherwise defined
herein shall have the meanings set forth in DRS Amendment No. 1.

The responses provided herein are based upon information provided to
Dorsey & Whitney LLP by the Company.

Draft Registration Statement on Form S-1

Cover Page

 1. You provide that you have applied to list your common stock on the OTCQB Venture Markets. This appears inconsistent with disclosure
elsewhere regarding proposed listing on OTCQX. Please revise or advise. Please also revise your disclosure here and throughout the filing,
including in the Risk Factors section, to discuss whether you will be considered a penny stock under Rule 3a51-1 of the Securities
Exchange Act of 1934 and the additional risks if you are deemed to be a penny stock. In addition, revise to make clear that OTC Markets
is a quotation medium for subscribing members, not an issuer listing service, and that only market makers can apply to quote securities.
If your offering is contingent upon quotation on the OTCQB Venture Markets, please make this clear on your cover.

The requested revisions have been made on the cover page and throughout DRS Amendment No. 1 in order to reflect that that Company has applied for its common shares to be quoted on the OTCQX.

The Company confirms that it will not be considered a penny
stock under Rule 3a51-1 of the Securities Exchange Act of 1934.

U.S. Securities and Exchange Commission

August 11, 2025

Page 2

 2. Please disclose on the cover page that you do not intend to apply for listing of the Warrants on any national securities exchange
or trading system, as referenced on page 7. Also, with respect to your disclosure that your subordinate voting shares are currently
quoted under the symbol “WAM” on the TSX Venture Exchange, or “TSXV,” please disclose the market price of your
subordinate voting shares as of the latest practicable date.

The requested revisions have been made on the cover page of
DRS Amendment No. 1.

Prospectus Summary, page 1

 3. Please clearly disclose here and in your risk factor section that the subordinate shares being registered in this offering are
part of a dual-class voting structure, in which holders of proportionate voting shares possess the voting equivalent of 100 subordinate
voting shares per every proportionate voting share held. Describe the potential risks of additional dilution if the holders of proportionate
voting shares convert their shares into 100 subordinate voting shares per every proportionate voting share held. Also provide a risk factor
disclosing, if true, that future issuances of proportionate voting shares may be dilutive to holders of subordinate voting shares.

The requested revisions have been made on pages 6
and 10 of DRS Amendment No. 1.

Implications of Being an Emerging
Growth Company, page 3

 4. We note your disclosure that after you cease to qualify as an emerging growth company, certain of the exemptions available to you
as an emerging growth company may continue to be available to you as a smaller reporting company. Please revise to provide attendant risk
factor disclosure.

The requested revisions have been made on page 13
of DRS Amendment No. 1.

U.S. Securities and Exchange Commission

August 11, 2025

Page 3

Risks Related to our Business,
page 11

 5. We note the discussion of the substantial doubt as to your ability to continue as a going concern reflected in the report of your
independent registered public accountant. Please revise to provide attendant risk factor disclosure.

The requested revisions have been made on page 14
of DRS Amendment No. 1.

Risk Factors

Certain of the directors and officers of ours also serve as directors
and/or officers of other companies..., page 28

 6. We note your disclosure that certain of your directors and officers also serve as directors and/or officers of other companies
involved in natural resource exploration and development and consequently there exists the possibility for such directors and officers
to be in a position of conflict. Please expand your disclosure to explain how you expect to resolve such conflicts.

The requested revisions have been made on page 28
of DRS Amendment No. 1.

Use of Proceeds, page 33

 7. We note your disclosure that the principal purposes of this offering are to obtain additional capital to support your operations;
that you intend to use the net proceeds from this offering to fund mining and exploration activities; and that you intend to use the remaining
proceeds to fund working capital and general corporate expenditures out of your existing cash reserves. Please clarify whether you intend
to use any of the proceeds from this offering to repay the $1,200,000 advance you received from a small group of existing shareholders,
or any amounts due under the Piek Promissory Note. If so, provide all of the disclosure required by Item 504 of Regulation S-K.

The requested revisions have been made on pages 6
and 32 of DRS Amendment No. 1.

Management's Discussion and Analysis of Financial Condition and
Results of Operations Our Business, page 37

 8. You state that you have no substantial revenue. However in other sections of the filing, for example, on page 47 you state
that you have no operating revenue. Similarly, on page 24 you state that you have only generated modest revenues. Please revise to
accurately reflect your historical revenue generation or explain the inconsistencies in your disclosure.

The requested revisions have been made on pages 16
and 36 of DRS Amendment No. 1 to clarify that the Company does not have any operating revenue.

U.S. Securities and Exchange Commission

August 11, 2025

Page 4

Governmental Approvals and Regulations,
page 46

 9. We note your disclosure that mining operations and exploration activities in the United States are subject to various federal,
state and local laws and regulations which govern prospecting, development, mining, production, exports, taxes, labor standards, occupational
health, waste disposal, protection of the environment, mine safety, hazardous substances and other matters. Please expand your disclosure
to better describe these individual regulations to the extent they are material to your business and operations. Refer to Item 101(h)(4)(viii) of
Regulation S-K.

The noted disclosure in the Registration Statement is intended
to generally describe the types of regulations that are, or that could become, applicable to mining companies generally. However, since
the Company is currently an exploration stage company, such regulations are currently not material to the Company’s business and
operations. Therefore, the Company respectfully submits that in response to the Staff’s comment, additional disclosure regarding
these individual regulations is not required to be included in DRS Amendment No. 1.

 Business

Description of Business

Status of Development Efforts,
page 47

 10. Please significantly expand your disclosure in this section to provide anticipated timelines, milestones, and the current status
of each of your projects. Refer to Item 101(h) of Regulation S-K.

The requested revisions have been made on page 48
of DRS Amendment No. 1.

Properties, page 48

 11. We note your disclosure on page 48 suggesting that you have other key mineral resource projects in other jurisdictions within
the United States. Please expand your summary disclosure to include all of your mineral properties, including a map showing the locations
of all properties, pursuant to Item 1303(b) of Regulation S-K.

The requested revisions have been made on page 50
of DRS Amendment No. 1, and the requested map has been included in DRS Amendment No. 1.

The Company has also revised the disclosure in DRS Amendment
No. 1 to clarify that all of its key mineral resource projects are in Alaska, and that it does not have any key mineral resource
projects “in other jurisdictions within the United States”.

U.S. Securities and Exchange Commission

August 11, 2025

Page 5

 12. Please expand your description of the Illinois Creek Project to summarize the work that you have completed on the property, consistent
with Item 1304(b)(2) of Regulation S-K.

The requested revisions have been made on page 51
of DRS Amendment No. 1.

 13. We note your disclosure on page 55, indicating that historical quality assurance/quality control (QA/QC) programs are lacking
or poorly documented. Item 1305 requires a summary of the internal controls related to exploration and mineral resource and reserve estimation
efforts. Considering that you have performed exploration work and have determined mineral resources, it appears the disclosure on page 55
should be consistent with the quality assurance and quality control disclosure on page 52. Please advise.

The requested revisions have been made on page 59
of DRS Amendment No. 1.

Management, page 56

 14. You provide on page 28 that certain of your officers and directors also serve as directors and/or officers of other companies
involved in natural resource exploration and development. Please expand your disclosure in this section to detail each title or position
held, and the length of time the position has been held.

The requested revisions have been made to the Management section
of DRS Amendment No. 1.

 15. Please revise your disclosure to describe the business experience during the past five years for each director, executive officer,
and named significant employees, including the principal occupations and employment during the past five years. See Item 401(e) of
Regulation S-K.

The requested revisions have been made to the Management section
of DRS Amendment No. 1.

Certain Relationships and Related
Transactions, page 66

 16. You provide that, except for compensation arrangements for your directors and executive officers, there have been no related party
transactions in your two most recently completed fiscal years. However, you provide on page 41 that, subsequent to December 31,
2024, the Company was issued an advance of $1,200,000 from a small group of existing shareholders to sustain general and administrative
costs until the Company is able to complete an equity financing in the spring of 2025. Please provide supplemental discussion as to why
this advance is not a related party transaction, or, if it is, please provide the disclosure required under Item 404 of Regulation S-K.

The requested revisions have been made on page 75
of DRS Amendment No. 1.

Out of the $1,200,000 advanced to the Company, the only
amount that qualified as a related party transaction within the meaning of Item 404 of Regulation S-K is $125,000 that was advanced to
the Company by the Company’s President & CEO and his wife. The remaining portion of the advance was provided by several
separate individuals who acted independently, none of which individually qualified as a related party transaction.

U.S. Securities and Exchange Commission

August 11, 2025

Page 6

Description of Securities, page 69

 17. Please revise to include risk factor disclosure regarding any potential material dilutive effect(s) of the outstanding Warrants
and Finder Warrants.

The requested revisions have been made on page 10
of DRS Amendment No. 1.

Note 1. Nature and Continuance
of Operations, page F-9

 18. You refer to the company as Western Alaska Minerals Corp. or “WAM” in the financial statements which is not consistent
with your recent name change to Alaska Silver Corp and the disclosure on page 2 and elsewhere in the filing. Please explain or revise.
Also, please define “WACG” where it is first used on page 37.

The Company has revised the disclosure throughout DRS Amendment
No. 1, other than in the financial statements and notes thereto, to reflect its recent name change.

In response to the Staff’s comment,
the Company proposes to make the revisions to the consolidated financial statements and notes thereto that are indicated in Exhibit A
to this letter.

Note 2. Basis of Presentation
and Material Accounting Policies Loss Per Share, page F-12

 19. You state that the Proportional Voting Shares have voting and economic rights on an as-converted basis and are, in effect, Subordinate
Voting Shares compressed at the ratio of 100:1. You also state that diluted loss per share is calculated by the treasury stock method.
Please respond to the following:

 · Tell us your consideration of ASC 260-10-45-59A through 45-70 in identifying participating securities and the use of the two-class
method. Also, please consider revising your accounting policy to address this matter accordingly.

 · In a separate footnote, provide the disclosures required by ASC 260-10-50-1 through 2 that support your calculation of loss per
share.

The Company respectfully submits that
because proportionate voting shares are entitled to vote and are entitled to dividends as if decompressed, they meet the definition of
a participating security as per ASC 260-10-45.

Based on its assessment of ASC 2610-45,
the Company concluded that under the two-class method, presentation of loss per share for proportionate voting shares should be included
in the weighted average number of shares outstanding and would affect the loss per share.

U.S. Securities and Exchange Commission

August 11, 2025

Page 7

In response to the Staff’s comment,
the Company proposes to make the revisions to the consolidated financial statements and notes thereto that are indicated in Exhibit A
to this letter. Specifically, the Company proposes to revise the consolidated financial statements in order to update the loss per share
and the weighted average number of shares outstanding to include, on an as converted basis, the proportionate voting shares. Further,
the Company proposes to add a table in Note 9 to reconcile the weighted average number of shares, including showing subordinate voting
shares and proportionate voting shares.

Note 6. Related Party Transactions,
page F-15

 20. You state that as at December 31, 2024, $722,989 (2023 – $523,757) is included in accounts
payable and accrued liabilities. However, we note these amounts are separately presented in the balance sheet as due to related parties.
Please revise to provide a description of these related party transactions and other related disclosures to comply with ASC paragraphs
850-10-50-1 through 50-4. Additionally, we note that under the section “Certain Relationships and Related Transactions” at
page 66, you state that except for compensation arrangements there have been no related party transactions in your two most recently
completed financial years. Please revise this section to provide information that is consistent with your financial statement disclosures.

In response to the Staff’s comment,
the Company proposes to make the revisions to Note 6 that are indicated in Exhibit A to this letter.

The Company respectfully notes that
all the related party trans