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 January 6, 2026

Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, Illinois 60606

 Re: Coeur Mining, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-08641
Dear Thomas S. Whelan:

 We have completed our review of your filing. We remind you that the
company and
its management are responsible for the accuracy and adequacy of their
disclosures,
notwithstanding any review, comments, action or absence of action by the staff.

 Sincerely,

 Division of Corporation
Finance
 Office of Energy &
Transportation
</TEXT>
</DOCUMENT>

CORRESP
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 filename1.htm

 Gibson, Dunn & Crutcher LLP

 200 Park Avenue

 New York, NY 10166-0193

 Tel 212.351.4000

 www.gibsondunn.com

 December 22, 2025

 VIA EMAIL AND EDGAR

 Ranjit Singh Pawar
 Jennifer O’Brien
 Office of Energy & Transportation
 Division of Corporation Finance
 U.S. Securities and Exchange Commission
 100 F Street, NE
 Washington, D.C. 20549-3628

 Re:

 Coeur Mining, Inc.

 Form 10-Q for the Fiscal Quarter Ended September 30, 2025

 Form 10-K for the Fiscal Year Ended December 31, 2024

 File No. 001-08641

 Dear Mr. Pawar and Ms. O’Brien:

 On behalf of Coeur Mining, Inc. (the “ Company ”) set forth below are responses to comments the staff (the “ Staff ”) of the Securities and Exchange Commission delivered by letter, dated December 12, 2025, with respect to the above
 referenced Form 10-K and Form 10-Q (the “ Comment Letter ”). The Company’s responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comment in the Comment Letter.

 Form 10-K for the Fiscal Quarter Ended September 30, 2025
 Non-GAAP Financial Performance Measures, page 42

 Comment #1:

 We note your response to prior comment 1 regarding your adjustment for “Acquired inventory purchase price” and do not agree with your conclusion. We continue to believe that this adjustment is
 inconsistent with Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. As such, please remove this adjustment from your non-GAAP measures, including Adjusted net income (loss), Adjusted EBITDA, and
 Adjusted costs applicable to sales.

 Response #1:

 The Company notes the Staff’s comment and respectfully confirms that it will remove the adjustment for “Acquired Inventory Purchase Price” in calculations of its non-GAAP financial measures, including Adjusted net
 income (loss), Adjusted EBITDA, and Adjusted costs applicable to sales, in its subsequent filings and earnings press releases.

 If we can be of any further assistance, or if you have any questions regarding the concerns detailed in this letter, please do not hesitate to call me at (212) 351-2389.

 Sincerely,

 /s/ Eric Scarazzo

 Eric Scarazzo

 cc:

 Casey Nault

 Coeur Mining, Inc.

 Senior Vice President, General Counsel and Secretary

December 12, 2025
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, Illinois 60606
Re:Coeur Mining, Inc.
Form 10-Q for the Fiscal Quarter Ended September 30, 2025
Form 10-K for the Fiscal Year Ended December 31, 2024
Response dated September 3, 2025
File No. 001-08641
Dear Thomas S. Whelan:
            We have reviewed your September 3, 2025 response to our comment letter and have
the following comment.
            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
August 5, 2025 letter
Response dated September 3, 2025
Form 10-Q for the Fiscal Quarter Ended September 30, 2025
Non-GAAP Financial Performance Measures, page 42
1.We note your response to prior comment 1 regarding your adjustment for
“Acquired inventory purchase price” and do not agree with your conclusion. We
continue to believe that this adjustment is inconsistent with Question 100.04 of the
Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. As
such, please remove this adjustment from your non-GAAP measures, including
Adjusted net income (loss), Adjusted EBITDA, and Adjusted costs applicable to sales.

December 12, 2025
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Ranjit Singh Pawar at 202-551-2702 or Jennifer O'Brien at 202-551-
3721 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

CORRESP
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      September 3, 2025

      VIA EMAIL AND EDGAR

      Ranjit Singh Pawar

      Jennifer O’Brien

      Office of Energy & Transportation

      Division of Corporation Finance

      U.S. Securities and Exchange Commission

      100 F Street, NE

      Washington, D.C. 20549-3628

            Re:

              Coeur Mining, Inc.

                Form 10-Q for the Fiscal Quarter Ended March 31, 2025

                Form 10-K for the Fiscal Year Ended December 31, 2024

                File No. 001-08641

      Dear Mr. Pawar and Ms. O’Brien:

      On behalf of Coeur Mining, Inc. (the “Company”), set forth below are responses to additional comments the staff (the “Staff”) of the Securities and Exchange Commission delivered by letter, dated August 5, 2025 (the “Comment
          Letter”), with respect to the above referenced Form 10-K and Form 10-Q. The Company’s responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comment in the Comment Letter.

      Response dated July 11, 2025

      Form 10-Q for the Fiscal Quarter Ended March 31, 2025

      Non-GAAP Financial Performance Measures, page 38

      Comment #1:

      We note your response to prior comment 1 regarding the adjustment for “Acquired inventory purchase price.” However, we do not agree that this adjustment is appropriate within the context of Question
        100.04 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please revise your presentation to remove this purchase accounting adjustment from your Adjusted net income (loss) and Adjusted EBITDA measures.

            Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

      Response #1:

      The Company acknowledges the Staff’s comment and advises the Staff that it has considered the guidance set forth in Question 100.04 of the Compliance and Disclosure Interpretations (“C&DI”) on Non-GAAP Financial Measures and the requirements
        set forth in Item 10(e) of Regulation S-K. Based on that guidance, the Company does not believe that it is tailoring the recognition or measurement principles required to be applied in accordance with GAAP in our Adjusted net income (loss) and
        Adjusted EBITDA calculation (or Adjusted Costs Applicable to Sales (“CAS”), which the Staff has indicated also is relevant), but rather is excluding the impacts of the non-recurring purchase price allocation to acquired inventory to provide users
        of our financial disclosures a better ability to assess the normal, recurring operating and cash flow profile of the high-grade and low-cost Las Chispas Gold and Silver Mine (“Las Chispas”) in Mexico.

      The matter in question arises from Coeur Mining, Inc’s $1.5 billion acquisition of SilverCrest Metals, Inc. and its key asset, Las Chispas. The fact that the production costs of the mine are low was one of the most compelling elements of the
        rationale for the acquisition, and the period-to-period operating cost profile of Las Chispas is a key focus of investors. Investors have asked for information sufficient to help them assess the historical cost of production.

      In accordance with ASC 805, we have allocated the purchase price across the acquired assets and assumed liabilities of SilverCrest, which included $144.6 million of acquired metal inventory that had a historical cost basis of approximately $51.2
        million. This resulted in a $93.5 million step up in cost basis to the existing ore stockpile, in-circuit and finished goods inventory, which step-up does not reflect the historical cost of producing such inventory and instead reflects the
        estimated fair value of such inventory on the date of acquisition.

      As of June 30, 2025, we have processed nearly 90% of the acquired metal inventory since the closing of the transaction on February 14, 2025, and expect to have processed the remaining material by the end of the third quarter, which aligns with
        the 5 months needed to process and sell the acquired stockpile material.

      In addition to providing GAAP numbers, as is required and appropriate, we have used our supplemental disclosures to address investors’ legitimate interest in understanding the normal, historical, recurring operating cost and margin profile of
        Las Chispas by also providing non-GAAP Adjusted CAS per ounce, to back out the amortized inventory step-up (i.e., the acquired inventory purchase price allocation), and to add back the amortized inventory step-up to Adjusted net income (loss) and
        Adjusted EBITDA.

      We believe providing Adjusted CAS, Adjusted net income (loss) and Adjusted EBITDA disclosure exclusive of the effects of the step-up in cost basis is appropriate for the following reasons:

            1.

              It creates a clear and transparent disclosure that allows users of our financial statements to compare Las Chispas’s normal, historical, recurring cash operating costs and operating margin from period to period, including pre- and
                post-acquisition, and to compare against operating mines of industry peers; and

            2.

              Investors and analysts have specifically asked for this information, so they can make the comparison referenced in point (1).

            Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

      Las Chispas prior to the acquisition historically had a very low CAS; for example, in 2024 the unit costs were $734 per ounce of gold and $8.62 per ounce of silver, respectively, and are forecasted for 2026 to be approximately $900 per ounce of
        gold and $9.00 per ounce of silver, respectively. However, due to the impact of the non-recurring inventory step-up recognized under acquisition accounting, the GAAP costs applicable to sales for Las Chispas in 2025 increased to $1,962 per ounce of
        gold and $20.93 per ounce of silver for the six months ended June 30, 2025, which includes the impact of the amortization of $56.7 million of the $93.5 million of inventory step-up expensed during that time. In this circumstance, a user of solely
        our GAAP financial statements will, in our view, not have an accurate understanding of the historical and future cost and cash flow profile of Las Chispas because using the GAAP costs per ounce to project for future performance would suggest that
        production costs are likely to be more than double what they have historically been, solely as a result of acquisition adjustments based on the fair value of the acquired inventory, which is not true and risks misleading investors into concluding
        that Las Chispas is now a high-cost mine post-acquisition.

      Based on feedback received since the acquisition closed, investors and analysts have focused primarily on understanding the normal, historical recurring operating cost and margin profile of Las Chispas, as reflected in the non-GAAP measures we
        are providing, rather than the GAAP cost and margin profiles, which are tied to a short-term period and depend upon non-cash purchase price accounting.   The 2025 GAAP CAS per ounce amounts for  gold and silver increased over 2024 levels by $1,106
        and $11.80, respectively, due to the non-recurring inventory step-up, or more than double the recurring normal underlying CAS unit cost metric.  This short-term elevated GAAP cost profile is not indicative of historical or expected future costs at
        Las Chispas.

      We do not believe the adjustments we have made to CAS, EBITDA and Net Income represent tailoring or misleading measures under C&DI Question 100.04 or the Staff’s other applicable guidance.  The adjustments are clear and transparent, the
        reasons for making the adjustments are easily understood, the adjusted measures provide information to investors which they have told us they want in order to understand the period-to-period normal, recurring cost profile of Las Chispas, and we
        believe investors have sufficient information to decide for themselves whether and how to use the adjusted measures.

      As is required and appropriate, we also provide the corresponding GAAP measures with equal or greater prominence, with clear reconciliations and other disclosures required by applicable rules.  However, we believe it may harm investors to
        prohibit the Company from providing supplemental adjusted measures that they have indicated are more relevant to an evaluation of the company’s trends in operating and financial performance.  Indeed, we understand that investors and analysts
        exclude the impact of the inventory step-up in their external models that form the basis for projections of Coeur’s 2025 results that support their investment decisions and recommendations.  We also note that the banks in our revolving credit
        facility similarly view the adjusted measures as highly relevant, by excluding the impact of the inventory step-up from the calculation of EBITDA for purpose of our net leverage ratio covenant, which governs ability to borrow under the facility.
        We believe the adjusted measures our investors and lenders deem highly relevant and useful are not misleading, particularly when presented along with the required GAAP disclosures.

            Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

      Response dated July 11, 2025

      Form 10-Q for the Fiscal Quarter Ended March 31, 2025

      Non-GAAP Financial Performance Measures, page 38

      Comment #2:

      We note your response to prior comment 2 regarding inventory adjustments. Please reconcile the inventory adjustment amounts for the Rochester mine in the table of your response on page 4 to the
        inventory adjustments excluded from Adjusted costs applicable to sales. For example, we note the inventory adjustment for 2023 of $(104) in your response does not agree with the adjustment in the 2024 earnings release of $(17,305). For 2022, we
        note the adjustment of $1,273 in your response is not equal to the amount disclosed in the 2023 earnings release of $(9,232).

      Response #2:

      We respectfully note that the inventory adjustments included in the Adjusted costs applicable to sales for Rochester include the inventory adjustment noted in our response to prior comment 2 as well as a portion of the inventory write-down.
        When presenting Adjusted costs applicable to sales we exclude only the final quarter inventory write-down.  A reconciliation of the inventory adjustment amounts is provided below:

              Year Ended December 31,

               2024

               2023

               2022

              Inventory adjustments

              $

              (2,746

              )

              $

              104

              $

              (1,273

              )

              Inventory write-downs 1

              -

              (17,409

              )

              (7,959

              )

              Rochester inventory adjustments

              $

              (2,746

              )

              $

              (17,305

              )

              $

              (9,232

              )

              1 - Represents the inventory write-down recognized in the fourth quarter of 2023 and 2022. There was no fourth quarter 2024 inventory write-down.

      If we can be of any further assistance, or if you have any questions regarding the concerns detailed in this letter, please do not hesitate to contact me or Casey M. Nault.

              Sincerely,

              /s/ Thomas S. Whelan

              Thomas S. Whelan

              Senior Vice President and Chief Financial Officer

            cc:

              Casey M. Nault, Senior Vice President, General Counsel and Secretary

                Eric Scarazzo, Gibson, Dunn & Crutcher LLP

          Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

CORRESP
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    August 14, 2025

    VIA EDGAR SUBMISSION

    Division of Corporation Finance

    Office of Energy & Transportation

    Securities and Exchange Commission

    100 F Street NE

    Washington, D.C. 20549

          Re:

            Coeur Mining, Inc.

    Form 10-Q for the Fiscal Quarter Ended March 31, 2025

    Form 10-K for the Fiscal Year Ended December 31, 2024

    Response dated July 11, 2025

    File No. 001-08641

    Dear Mr. Pawar and Ms. O'Brien:

    Coeur Mining, Inc. (the “Company”) is in receipt of the comment letter dated August 5, 2025 (the “Letter”) from the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission regarding
      the above-referenced filings.

    On behalf of the Company, I hereby request that the Staff permit the Company to provide its response to the comments by September 3, 2025, which is ten business days after the initial deadline set forth in the Letter.

    If you have any questions, please do not hesitate to contact our counsel at Gibson, Dunn & Crutcher LLP, Eric Scarazzo at (212) 351-2389.

            Very truly yours,

            /s/ Thomas S. Whelan

            Thomas S. Whelan

            Senior Vice President and Chief Financial Officer

          cc:

            Casey M. Nault, Senior Vice President, General Counsel and Secretary

    Eric Scarazzo, Gibson, Dunn & Crutcher LLP

    Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

August 5, 2025
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, Illinois 60606
Re:Coeur Mining, Inc.
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Form 10-K for the Fiscal Year Ended December 31, 2024
Response dated July 11, 2025
File No. 001-08641
Dear Thomas S. Whelan:
            We have reviewed your July 11, 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
June 26, 2025 letter
Response dated July 11, 2025
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Non-GAAP Financial Performance Measures, page 38
1.We note your response to prior comment 1 regarding the adjustment for “Acquired
inventory purchase price.” However, we do not agree that this adjustment is
appropriate within the context of Question 100.04 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures. Please revise your presentation to
remove this purchase accounting adjustment from your Adjusted net income (loss)
and Adjusted EBITDA measures.

August 5, 2025
Page 2
Form 10-K for the Fiscal Year Ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Performance Measures, page 57
2.We note your response to prior comment 2 regarding inventory adjustments. Please
reconcile the inventory adjustment amounts for the Rochester mine in the table of
your response on page 4 to the inventory adjustments excluded from Adjusted costs
applicable to sales. For example, we note the inventory adjustment for 2023 of $(104)
in your response does not agree with the adjustment in the 2024 earnings release of
$(17,305). For 2022, we note the adjustment of $1,273 in your response is not equal to
the amount disclosed in the 2023 earnings release of $(9,232).
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Ranjit Singh Pawar at 202-551-2702 or Jennifer O'Brien at 202-551-
3721 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

CORRESP
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    July 11, 2025

    VIA EMAIL AND EDGAR

    Ranjit Singh Pawar

    Jennifer O’Brien

    Office of Energy & Transportation

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549-3628

          Re:

            Coeur Mining, Inc.

            Form 10-Q for the Fiscal Quarter Ended March 31, 2025

              Form 10-K for the Fiscal Year Ended December 31, 2024

              File No. 001-08641

    Dear Mr. Pawar and Ms. O’Brien:

    On behalf of Coeur Mining, Inc. (the “Company”), set forth below are responses to additional comments the staff (the “Staff”) of the Securities and Exchange Commission delivered by letter, dated June 26, 2025 (the “Supplemental
        Letter”), with respect to the above referenced Form 10-K and Form 10-Q originally set forth in a letter from the Staff dated May 28, 2025 (the “Comment Letter”). The Company’s responses to the Staff’s comments are set forth below, with
      each paragraph numbered to correspond to the numbered comment in the Comment Letter.

    Response dated June 11, 2025

    Form 10-Q for the Fiscal Quarter Ended March 31, 2025

    Non-GAAP Financial Performance Measures, page 38

    Comment #1:

    We note your response to prior comment 5 regarding the adjustment for “Acquired inventory purchase price.” Please further clarify why you believe an adjustment for “a five-month short-term stockpile of
      ore that is expected to be consumed during the first year of ownership” does not change the recognition and measurement principles required to be applied in accordance with GAAP. Refer to Question 100.04 of the Compliance and Disclosure
      Interpretations on Non-GAAP Financial Measures. Alternatively, please revise your presentation to remove this purchase accounting adjustment.

        Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606 | 312.489.5800 |
          www.coeur.com

    Response #1:

    The Company acknowledges the Staff’s comment and advises the Staff that it has considered the guidance set forth in Question 100.04 of the Compliance and Disclosure Interpretations (“C&DI”) on Non-GAAP Financial Measures and the requirements
      set forth in Item 10(e) of Regulation S-K.  Based on that guidance, the Company does not believe that it is tailoring the recognition or measurement principles required to be applied in accordance with GAAP in our Adjusted EBITDA calculation, but
      rather is excluding the impacts of the non-cash purchase price allocation to acquired inventory, which provides users of our financial disclosures – including investors who have specifically requested this information – an understanding of our
      ongoing operating performance.

    As part of the purchase price allocation, the Company recognized a non-cash $93.3 million increase in the carrying value of the acquired metal inventory which included finished goods, work in process and a short-term stockpile of ore.  In the
      first quarter of 2025, $27.0 million of the $93.3 million was recognized in the condensed consolidated statement of comprehensive income as part of costs applicable to sales and was included as an adjustment to Adjusted EBITDA. The full amount of the
      acquired metal inventory purchase price allocation is expected to be recognized as an expense in the first year following the acquisition date and would not have a recurring impact on metal inventory in subsequent years. We believe our adjustment,
      which excludes the nonrecurring impact of the non-cash purchase price allocation to acquired inventory, does not make the non-GAAP measure misleading because: (i) the adjustment excludes the GAAP impact of only the portion of the allocation that was
      recognized in the condensed consolidated statement of comprehensive income, without changing the amount or timing, (ii) the excluded GAAP result is not reflective of recurring cash operating expenses, and (iii) the disclosure is transparent, such
      that investors can determine for themselves how much weight to provide to the adjustment.

    The adjustment is not intended to, and in our view it does not, smooth or alter results. Therefore, we believe that the adjustment is not misleading under the guidance in C&DI Question 100.4 but rather gives users of our financial disclosures
      a better understanding of normal, recurring operating margins and results of operations.  This has been validated by investor requests for this information since the closing of the acquisition to help them understand whether normal, recurring
      operating costs post-acquisition are expected to be similar to those pre-acquisition under prior ownership.

    Furthermore, the Company considered the guidance set forth in Question 102.09 of the C&DI on Non-GAAP Financial Measures and the requirements set forth in Item 10(e) of Regulation S-K.  As further discussed below, Adjusted EBITDA is the basis
      of one of the financial covenants in the Company’s revolving credit facility (“RCF”), and the RCF allows for the inclusion of acquired inventory purchase price as an adjustment to Adjusted EBITDA when calculating the financial covenant to determine
      compliance and the Company’s ability to continue to draw funds from the RCF.

        Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606 | 312.489.5800 |
          www.coeur.com

    Response dated June 11, 2025

    Form 10-K for the Fiscal Year Ended December 31, 2024

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

    Non-GAAP Financial Performance Measures, page 57

    Comment #2:

    We note from your response to prior comment 4 that the adjustment titled “Inventory adjustments and writedowns” represents amounts that you deemed incremental to normal operations within the context of
      Question 100.01 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Please address the following:

          (a)

            Provide further clarity as to the nature of the individual components of the adjustment for each of the reporting periods 2022 through 2024. To this end, provide us with a breakdown, including quantification,
              that distinguishes between inventory adjustments and inventory writedowns. For inventory adjustments, clarify whether they are adjustments related solely to the Rochester expansion project, or otherwise advise.

    Response #2(a):

    Inventory adjustments and write-downs are made up of two distinct components - inventory adjustments and inventory write-downs.

    Inventory adjustments represent the Company’s reserve for obsolete supply inventory across all mining sites. The reserve is calculated on a quarterly basis following an analysis of the aging of the supply inventory at each mining site.

    Inventory write-downs are related to the calculation of net realizable value of the Company’s metal inventory. Metal inventory is stated at lower of cost or net realizable value, with cost being determined using a weighted average cost method. Net
      realizable value represents the estimated future sales price based on short-term and long-term metal prices, less estimated costs to complete production and bring the product to sale. The inventory write-downs related entirely to unusual and atypical
      operating conditions at Rochester during the expansion project, which explains why inventory write-downs trailed off significantly in 2024 as the expansion project wrapped up.

        Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606 | 312.489.5800 |
          www.coeur.com

    The following table provides a breakdown of inventory write-downs and inventory adjustments.

            Year Ended December 31,

             2024

            2023

            2022

            Inventory write-downs - Rochester

            $

            3,153

            $

            39,876

            $

            45,978

            Inventory adjustments - Rochester

            2,746

            (104

            )

            1,273

            Inventory adjustments - Palmarejo

            1,365

            933

            599

            Inventory adjustments - Kensington

            361

            988

            401

            Inventory adjustments - Wharf

            126

            653

            217

            Inventory adjustments - Silvertip

            291

            842

            617

            $

            8,042

            $

            43,188

            $

            49,085

          (b)

            For the components you described in your response related to the “initial decrease in production resulting from lower throughput rates and higher than planned crushed sizes,” and elevated costs incurred during
              the construction and start-up phases of the Rochester expansion project, including mechanical failures and design modifications, tell us more about why you do not deem these to be normal operating expenses that can occur during a mine
              expansion project. As part of your response, clarify whether you deem these costs “unusual and atypical” because they were unexpected expenses that arose when compared to your mine plan or otherwise advise.

    Response #2(b):

    Based on the Company’s historical experience operating the Rochester mine, we believe that the reduced production and increased costs were unusual and atypical because they were driven by changes to the mine plan and operating conditions that
      arose as a direct result of the expansion project.

    Rochester is an open pit heap leach operation with multiple leach pads. The legacy leach pads are in various stages of their production cycle and continued production from the legacy leach pads is significantly impacted by the ability to place new
      recoverable gold and silver to replace produced gold and silver.  Additionally, the recovery rates associated with new recoverable gold and silver placed are impacted by crush size of the placed ore.

        Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606 | 312.489.5800 |
          www.coeur.com

    Operating cashflow from production off Rochester’s legacy leach pads was expected to be a significant source of funding for the mine’s expansion project.  This expectation was based on the assumption that Rochester would continue to crush and
      place ore on the legacy leach pads during the construction phase of the expansion project at a rate consistent with pre-expansion project levels.  However, during the construction phase of the expansion project, Rochester was unable to execute its
      mine plan and maintain a sufficient level of production to support the existing and at times higher costs that were incurred.  Ore tons placed were 18%, 24% and 10% lower than planned in 2022, 2023 and 2024, respectively.  The lower production
      resulted in a temporary increase in the unit cost of gold and silver produced.  Factors that contributed to the lower production included unexpected changes to the mine plan caused by unforeseen interruptions to mining activities due to the
      overlapping footprint of the ongoing operations and the expansion project that interfered with Rochester’s ability to execute its planned mining and crushing activities, longer than expected down time of the existing crushing circuit that was used to
      feed both new recoverable gold and silver placed on the legacy leach pads as well as provide crushed material to the new leach pad during the construction phase, and an earlier-than-planned dismantle of the existing crushing circuit to allow for
      mining in the area around the existing crushing circuit that resulted in a period of time when Rochester had no operating crushing circuit.  These factors contributed to a deficit in new ore placed compared to production from the legacy leach pads,
      which was a significant factor in the inventory write-downs from 2022-2024.

          (c)

            Clarify how you quantified the amounts for inventory adjustments and/or inventory write-downs related to “initial decrease in production resulting from lower throughput rates and higher than planned crushed
              sizes.”

    Response #2(c):

    The calculation of an inventory write-down includes a number of inputs including recoverable gold and silver on the leach pads, short-term and long-term gold and silver prices, and costs of production, including an estimated cost to complete. The
      estimated cost per ounce of gold and silver is then compared to the estimated realizable sale price of each ounce of gold and silver to determine if there is a required inventory write-down.

    During the period from 2022-2024, this analysis resulted in the estimated cost per ounce of gold and silver that exceeded the estimated realizable sale price of the gold and silver produced. The primary cause of inventory write-downs was a
      reduction in ore tons placed and the corresponding reduction in production from the legacy leach pads and, to a lesser extent, the incrementally higher costs incurred in the production process. Not until the new crushing circuit that was built as
      part of the expansion project was placed into commercial production in early 2024 was the balance between the newly placed and gold and silver production re-established, which has led to no further inventory write-downs at Rochester as of the second
      quarter of 2024.

          (d)

            You note that your revolving credit facility covenant calculation of Adjusted EBITDA allows for the inclusion of this adjustment. Please clarify whether you believe that the credit agreement is a material
              agreement, that the covenant is a material term of the credit agreement, and that information about the covenant is material to an investor’s understanding of your financial condition and/or liquidity. Refer to Question 102.09 of the
              Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

        Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606 | 312.489.5800 |
          www.coeur.com

    Response #2(d):

    The Company acknowledges the Staff’s comment and advises the Staff that it has considered the guidance set forth in Question 102.09 of the C&DI on Non-GAAP Financial Measures and the requirements set forth in Item 10(e) of Regulation S-K.
      Based on that guidance, the Company believes that the RCF is a material agreement, that the covenant is a material term of the RCF, and that information about the covenant is material to an investor’s understanding of the Company’s financial
      condition and liquidity.

    The Company considers the RCF to be a material agreement and has consistently reported it as such in its relevant filings. The RCF currently provides for up to $400 million in liquidity and was a major source of funding during the Rochester
      expansion project. The Company is required to comply with certain financial covenants in order to continue drawing funds from the RCF and engage in certain business activities. Adjusted EBITDA is the basis of one such financial covenant and the RCF
      specifically provides for the inclusion of inventory write-downs as an adjustment to Adjusted EBITDA when calculating the financial covenant to determine compliance and the Company’s ability to continue to draw funds from the RCF.  The Company
      negotiated amendments to the RCF with its creditors during the course of the Rochester expansion, including modifying relevant financial covenant levels and calculation methodology. Had the inventory write-downs been excluded from this calculation,
      the Company would likely have exceeded the allowable fina

June 26, 2025
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, Illinois 60606
Re:Coeur Mining, Inc.
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Form 10-K for the Fiscal Year Ended December 31, 2024
Response dated June 11, 2025
File No. 001-08641
Dear Thomas S. Whelan:
            We have reviewed your June 11, 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
May 28, 2025 letter
Response dated June 11, 2025
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Non-GAAP Financial Performance Measures, page 38
We note your response to prior comment 5 regarding the adjustment for “Acquired
inventory purchase price.” Please further clarify why you believe an adjustment for “a
five-month short-term stockpile of ore that is expected to be consumed during the first
year of ownership” does not change the recognition and measurement principles
required to be applied in accordance with GAAP. Refer to Question 100.04 of the
Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.
Alternatively, please revise your presentation to remove this purchase accounting
adjustment.1.

June 26, 2025
Page 2

Form 10-K for the Fiscal Year Ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Performance Measures, page 57
We note from your response to prior comment 4 that the adjustment titled “Inventory
adjustments and writedowns” represents amounts that you deemed incremental to
normal operations within the context of Question 100.01 of the Compliance and
Disclosure Interpretations on Non-GAAP Financial Measures. Please address the
following:

•Provide further clarity as to the nature of the individual components of the
adjustment for each of the reporting periods 2022 through 2024. To this end,
provide us with a breakdown, including quantification, that distinguishes between
inventory adjustments and inventory writedowns. For inventory adjustments,
clarify whether they are adjustments related solely to the Rochester expansion
project, or otherwise advise.

•For the components you described in your response related to the “initial decrease
in production resulting from lower throughput rates and higher than planned
crushed sizes,” and elevated costs incurred during the construction and start-up
phases of the Rochester expansion project, including mechanical failures and
design modifications, tell us more about why you do not deem these to be normal
operating expenses that can occur during a mine expansion project. As part of
your response, clarify whether you deem these costs “unusual and atypical”
because they were unexpected expenses that arose when compared to your mine
plan or otherwise advise.

•Clarify how you quantified the amounts for inventory adjustments and/or
inventory write-downs related to “initial decrease in production resulting from
lower throughput rates and higher than planned crushed sizes.”

•You note that your revolving credit facility covenant calculation of Adjusted
EBITDA allows for the inclusion of this adjustment. Please clarify whether you
believe that the credit agreement is a material agreement, that the covenant is a
material term of the credit agreement, and that information about the covenant is
material to an investor's understanding of your financial condition and/or
liquidity. Refer to Question 102.09 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures.

We note there is a quantitative difference between the “Inventory adjustments and
writedowns” made to derive Adjusted EBITDA and the “Inventory Adjustments”
made to derive Adjusted costs applicable to sales as presented in your earnings
release. For example, the amount of adjustment in 2024 to Adjusted EBITDA was •2.

June 26, 2025
Page 3
$8,042 whereas the amount of adjustment to Costs applicable to sales was $4,598.
Please explain to us the reason for using different inventory adjustment amounts
for these non-GAAP measures, and the nature of the differences.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact Ranjit Singh Pawar at 202-551-2702 or Jennifer O'Brien at 202-551-
3721 if you have questions regarding comments on the financial statements and related
matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

CORRESP
1
filename1.htm

    June 11, 2025

    VIA EMAIL AND EDGAR

    Ranjit Singh Pawar

    Jennifer O’Brien

    Office of Energy & Transportation

    Division of Corporation Finance

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549-3628

          Re:

            Coeur Mining, Inc.

              Form 10-K for the Fiscal Year Ended December 31, 2024

              Form 10-Q for the Fiscal Quarter Ended March 31, 2025

              Filed November 14, 2024

              File No. 001-08641

    Dear Mr. Pawar and Ms. O’Brien:

    On behalf of Coeur Mining, Inc. (the “Company”) set forth below are responses to comments the staff (the “Staff”) of the Securities and Exchange Commission delivered by letter, dated May 28, 2025, with respect to the above referenced
      Form 10-K and Form 10-Q (the “Comment Letter”). The Company’s responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comment in the Comment Letter.

    Form 10-K for the Fiscal Year Ended December 31, 2024

    Item 2. Properties, page 34

    Comment #1:

    Please revise subsequent filings to disclose the selected point of reference in which each of your mineral resources and mineral reserves are based, for example in situ, mill feed, saleable product,
      etc. as required by Item 1304(d)(1) of Regulation S-K.

    Response #1:

    The Company notes the Staff’s comment and respectfully confirms that it will revise its subsequent filings to disclose the selected point of reference as required by Item 1304(d)(1) of Regulation S-K.

          Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

    Comment #2:

    Please revise subsequent filings to compare each properties’ mineral resources and reserves as of the end of the last fiscal year with the mineral resources and reserves as of the end of the preceding
      year, and explain any material change between the two, as required by Item 1304(e) of Regulation S-K. Please provide a draft of your proposed changes with your response.

    Response #2:

    In response to the Staff’s comment, we have included below proposed language demonstrating the type of disclosure that we would plan to add to the end of each property description in Item 2 of future Form 10-K filings.

    Kensington

    As of December 31, 2024 and 2023, Kensington reported 501 thousand and 411 thousand ounces of gold reserves, respectively. The year-over-year increase of approximately 22% was primarily due to additions through resource conversion, partially
      offset by depletion.

    As of December 31, 2024 and 2023, Kensington reported 886 thousand and 819 thousand ounces of measured and indicated gold resources, respectively, and 228 thousand and 388 thousand ounces of inferred gold resources, respectively. The
      year-over-year increase of approximately 8% in measured and indicated gold resources was primarily due to conversion of inferred resources, while the approximately 41% decrease in inferred resources was primarily due to conversion to reserves.

    Wharf

    As of December 31, 2024 and 2023, Wharf reported 757 thousand and 763 thousand ounces of gold reserves, respectively. The year-over-year decrease of approximately 1% was primarily due to depletion partially offset by resource conversion.

    As of December 31, 2024 and 2023, Wharf reported 1.019 million and 498 thousand ounces of measured and indicated gold resources, respectively, and 470 thousand and 149 thousand ounces of inferred gold resources, respectively. The year-over-year
      increases of approximately 105% in measured and indicated gold resources and 216% of inferred gold resources were both primarily driven by additions of resources near areas where mining previously occurred during periods of low gold prices.

    Las Chispas

    As of December 31, 2024, Las Chispas reported 357 thousand ounces of gold reserves and 33.5 million ounces of silver reserves. No comparison can be made to mineral reserves as of December 31, 2023 because the Company has not previously reported
      the 2023 reserves under Item 1300 of Regulation S-K. SilverCrest Metals Inc., which the Company acquired in February 2025, did previously disclose reserves for Las Chispas, but it did so in compliance with Canada’s National Instrument 43-101.

          Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

    As of December 31, 2024, Las Chispas reported 156 thousand ounces of gold measured and indicated resources and 14.4 million ounces of silver measured and indicated resources, as well as 144 thousand ounces of gold inferred resources and 10.1
      million ounces of silver inferred resources.  No comparison can be made to mineral resources as of December 31, 2023 because the Company has not previously reported the 2023 resources under Item 1300 of Regulation S-K. SilverCrest Metals Inc. did
      previously report the 2023 resources but it did so in compliance with Canada’s National Instrument 43-101.

    Palmarejo

    As of December 31, 2024 and 2023, Palmarejo reported 681 thousand and 769 thousand ounces of gold reserves, respectively, and 46.0 million and 51.0 million ounces of silver reserves, respectively. The year-over-year decrease of approximately 11%
      in gold reserves and approximately 10% in silver reserves were both primarily due to depletion.

    As of December 31, 2024 and 2023, Palmarejo reported 1.423 million and 1.322 million ounces of measured and indicated gold resources, respectively, and 89.9 million and 85.6 million ounces of measured and indicated silver resources, respectively.
      The year-over-year increase of approximately 8% in gold measured and indicated resources and 5% in silver measured and indicate resources were each primarily driven by exploration growth and changes in cut-off grade. As of December 31, 2024 and 2023,
      Palmarejo reported 643 thousand and 381 thousand ounces of inferred gold ounces, respectively, and 34.7 million and 18.9 million ounces of silver inferred ounces, respectively. The year-over-year increases of approximately 69% in gold inferred ounces
      and 84% in silver inferred ounces were primarily due to exploration growth.

    Rochester

    As of December 31, 2024 and 2023, Rochester reported 1.298 million and 1.239 million ounces of gold reserves, respectively, and 191.0 million and 192.9 million silver reserves, respectively. The year-over-year increase of approximately 5% in gold
      reserves and decrease of approximately 1% in silver reserves were primarily due to mineral resource conversion offset by depletion and incorporation of the Lincoln Hill area, and its higher gold grades, into Rochester’s mineral reserve base.

    As of December 31, 2024 and 2023, Rochester reported 260 thousand and 247 thousand ounces of measured and indicated gold resources, respectively, and 36.9 million and 42.8 million ounces of measured and indicated silver resources, respectively.
      The year-over-year increase of approximately 5% in gold measured and indicated resources and decrease of approximately 14% in silver measured and indicated resources were driven by conversion to reserves and change in cut-off grade. As of December
      31, 2024 and 2023, Rochester reported 258 thousand and 267 thousand ounces of inferred gold ounces, respectively, and 41.8 million and 46.0 million ounces of silver inferred ounces, respectively. The year-over-year decrease of approximately 9% in
      gold inferred ounces and 3% in silver inferred ounces were due to conversion and incorporation of the Lincoln Hill area, and its higher gold grades, into Rochester’s mineral resource base.

          Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

    Silvertip

    As of December 31, 2024 and 2023, there were no changes to mineral reserves or mineral resources for Silvertip.

    Form 10-K for the Fiscal Year Ended December 31, 2024

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

    Non-GAAP Financial Performance Measures, page 57

    Comment #3:

    We note your reconciliation of Net income (loss) to Adjusted net income (loss) and to adjusted EBITDA. Please revise to clearly describe the nature and composition of the underlying adjustments in the
      “Other adjustments” reconciling line item for each year presented. Refer to Question 100.05 of the Compliance and Disclosure Interpretations on Non-GAAP Financial Measures.

    Response #3:

    In response to the Staff’s comment, we have included below revised reconciliations of Net income (loss) to Adjusted Net Income (Loss) and EBITDA and Adjusted EBITDA by removing the line item titled
      “Other adjustments” and replacing it with additional lines describing such other adjustments. We will revise our reconciliation disclosure in future filings to include the nature and composition of the underlying adjustments and eliminate the “Other
      adjustments” reconciling line item.

    Adjusted Net Income (Loss)

    Management uses Adjusted net income (loss) to evaluate the Company’s operating performance, and to plan and forecast its operations. The Company believes the use of Adjusted net income (loss)
      reflects the underlying operating performance of our core mining business and allows investors and analysts to compare results of the Company to similar results of other mining companies. Management’s determination of the components of Adjusted net
      income (loss) is evaluated periodically and is based, in part, on a review of non-GAAP financial measures used by mining industry analysts. The tax effect of adjustments are based on statutory tax rates and the Company’s tax attributes, including the
      impact through the Company’s valuation allowance. The combined effective rate of tax adjustments may not be consistent with the statutory tax rates or the Company’s effective tax rate due to jurisdictional tax attributes and related valuation
      allowance impacts which may minimize the tax effect of certain adjustments and may not apply to gains and losses equally. Adjusted net income (loss) is reconciled to Net income (loss) in the following table:

          Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

            Year Ended December 31,

            In thousands except per share amounts

            2024

            2023

            2022

            Net income (loss)

            $

            58,900

            $

            (103,612

            )

            $

            (78,107

            )

            Fair value adjustments, net

            —

            (3,384

            )

            66,668

            Foreign exchange loss (gain)

            (4,448

            )

            1,994

            1,648

            (Gain) loss on sale of assets and securities

            4,250

            25,197

            (64,429

            )

            RMC bankruptcy distribution

            (1,294

            )

            (1,516

            )

            (1,651

            )

            (Gain) loss on debt extinguishment

            (417

            )

            (3,437

            )

            —

            Transaction costs

            8,517

            —

            —

            Kensington royalty settlement

            7,369

            469

            —

            Mexico arbitration matter

            3,612

            2,803

            1,142

            Flow-through share premium

            (5,563

            )

            (2,284

            )

            —

            Legacy crusher disposal

            —

            4,013

            —

            COVID-19

            11

            111

            1,739

            Interest income

            —

            (187

            )

            (720

            )

            Tax effect of adjustments(1)

            (820

            )

            1,785

            (15,349

            )

            Adjusted net income (loss)

            $

            70,117

            $

            (78,048

            )

            $

            (89,059

            )

            Adjusted net income (loss) per share, Basic

            $

            0.18

            $

            (0.23

            )

            $

            (0.32

            )

            Adjusted net income (loss) per share, Diluted

            $

            0.18

            $

            (0.23

            )

            $

            (0.32

            )

    (1) For the year ended December 31, 2024, tax effect of adjustments of $(0.8) million (-5%) is primarily related to the RMC bankruptcy distribution, and nonrecurring
      expenses at Palmarejo. For the year ended December 31, 2023, tax effect of adjustments of $1.8 million (8%) is primarily related to the loss on the sale of the La Preciosa Deferred Consideration. For the year ended December 31, 2022, tax effect of
      adjustments of $(15.3) million (-558%) is primarily related to the to the fair value adjustments on the Company’s equity investments and the derecognition of deferred tax liabilities related to the sale of La Preciosa and the Sterling/Crown
      exploration properties.

    EBITDA and Adjusted EBITDA

    Management uses EBITDA to evaluate the Company’s operating performance, to plan and forecast its operations, and assess leverage levels and liquidity measures. The Company believes the use of EBITDA
      reflects the underlying operating performance of our core mining business and allows investors and analysts to compare results of the Company to similar results of other mining companies. Adjusted EBITDA is the basis of a measure used in the
      indenture governing the 2029 Senior Notes and the RCF to determine our ability to make certain payments and incur additional indebtedness. EBITDA and Adjusted EBITDA do not represent, and should not be considered an alternative to, Net income (Loss)
      or Cash Flow from Operations as determined under GAAP. Other companies may calculate Adjusted EBITDA differently and those calculations may not be comparable to our presentation. Adjusted EBITDA is reconciled to Net income (loss) in the following
      table:

          Coeur Mining, Inc. | 200 South Wacker Drive, Suite 2100 | Chicago, IL 60606| 312.489.5800 | www.coeur.com

            Year Ended December 31,

            In thousands

            2024

            2023

            2022

            Net income (loss)

            $

            58,900

            $

            (103,612

            )

            $

            (78,107

            )

            Interest expense, net of capitalized interest

            51,276

            29,099

            23,861

            Income tax provision (benefit)

            67,450

            35,156

            14,658

            Amortization

            124,974

            99,822

            111,626

            EBITDA

            302,600

            60,465

            72,038

            Fair value adjustments, net

            —

            (3,384

            )

            66,668

            Foreign exchange (gain) loss

            (4,753

            )

            459

            850

            Asset retirement obligation accretion

            16,778

            16,405

            14,232

            Inventory adjustments and write-downs

            8,042

            43,188

            49,085

            (Gain) loss on sale of assets and securities

            4,250

            25,197

            (64,429

            )

            RMC bankruptcy distribution

            (1,294

May 28, 2025
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, Illinois 60606
Re:Coeur Mining, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2024
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
File No. 001-08641
Dear Thomas S. Whelan:
            We have reviewed your filings 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.
Form 10-K for the Fiscal Year Ended December 31, 2024
Item 2. Properties, page 34
1.Please revise subsequent filings to disclose the selected point of reference in which
each of your mineral mineral resources and mineral reserves are based, for example in
situ, mill feed, saleable product, etc. as required by Item 1304(d)(1) of Regulation S-
K.
2.Please revise subsequent filings to compare each properties' mineral resources and
reserves as of the end of the last fiscal year with the mineral resources and reserves as
of the end of the preceding year, and explain any material change between the two, as
required by Item 1304(e) of Regulation S-K.  Please provide a draft of your proposed
changes with your response.

May 28, 2025
Page 2
Item 7. Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Performance Measures, page 57
3.We note your reconciliation of Net income (loss) to Adjusted net income (loss) and to
adjusted EBITDA. Please revise to clearly describe the nature and composition of the
underlying adjustments in the “Other adjustments” reconciling line item for each year
presented. Refer to Question 100.05 of the Compliance and Disclosure Interpretations
on Non-GAAP Financial Measures.
4.We note you include a reconciling item titled "Inventory adjustments and write-
downs" to derive Adjusted EBITDA. Please tell us how you concluded that inventory
adjustments and write-downs are not a normal recurring operating expense of your
operations. Refer to Question 100.01 of the Compliance and Disclosure
Interpretations on Non-GAAP Financial Measures.
Form 10-Q for the Fiscal Quarter Ended March 31, 2025
Non-GAAP Financial Performance Measures, page 38
5.We note you include a reconciling item titled "Acquired inventory purchase price" to
derive Adjusted net income (loss) and Adjusted EBITDA. However, it appears that
this adjustment eliminates the impact of GAAP purchase accounting and substitutes
individually tailored recognition and measurement methods. Please revise to remove
this adjustment or explain to us why you believe this adjustment is appropriate. Refer
to Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
            Please contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if
you have questions regarding the engineering comments. Please contact Ranjit Singh Pawar
at 202-551-2702 or Jennifer O'Brien at 202-551-3721 if you have questions regarding
comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

December 30, 2024
Mitchell J. Krebs
Chairman, President & Chief Executive Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, IL 60606
Re:Coeur Mining, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed November 14, 2024
Amendment No. 1 to Preliminary Proxy Statement on Schedule 14A
Filed December 13, 2024
File No. 001-08641
Dear Mitchell J. Krebs:
            We have completed our review of your filing. We remind you that the company and
its management are responsible for the accuracy and adequacy of their disclosures,
notwithstanding any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Eric Scarazzo, Esq.

CORRESP
1
filename1.htm

      December 13, 2024

      VIA EMAIL AND EDGAR

      Cheryl Brown

      Irene Barberena-Meissner

      Office of Energy & Transportation

      Division of Corporation Finance

      U.S. Securities and Exchange Commission

      100 F Street, NE

      Washington, D.C. 20549-3628

            Re:

              Coeur Mining, Inc.

                Preliminary Proxy Statement on Schedule 14A

                Filed November 14, 2024

                File No. 001-08641

      Dear Mses. Brown and Barberena-Meissner:

      On behalf of Coeur Mining, Inc. (the “Company”) set forth below are responses to comments the staff (the “Staff”) of the Securities and Exchange Commission delivered by letter, dated December 6, 2024, with respect to the above
        referenced Preliminary Proxy Statement on Schedule 14A (the “Comment Letter”). Filed concurrently herewith is Amendment No. 1 to the Preliminary Proxy Statement on Schedule 14A (the “Amended Preliminary Proxy Statement on Schedule 14A”),

        containing changes and revisions in response to the Staff’s comments. Capitalized terms used but not defined in this letter have the meanings given to them in the Amended Preliminary Proxy Statement on Schedule 14A, as applicable.

      The Company’s responses to the Staff’s comments are set forth below, with each paragraph numbered to correspond to the numbered comment in the Comment Letter. All references to page numbers and captions in these responses correspond to the
        Amended Preliminary Proxy Statement on Schedule 14A, as applicable (except for such page numbers and captions included in the Staff’s transposed comments).

      Preliminary Proxy Statement on Schedule 14A filed November 14, 2024

      Background of the Arrangement, page 60

            1.

              We note your disclosure that on September 18, 2023, Mr. Thomas Whelan, Senior Vice President and Chief Financial Officer of Coeur, who also heads Coeur’s Corporate Development team, held an introductory
                meeting with Mr. N. Eric Fier, the Chief Executive Officer and a director of SilverCrest, and Ms. Tara Hassan, P.Eng, the Vice President, Corporate Development of SilverCrest. We further note that on December 11, 2023, a representative of
                Cormark Securities Inc. indicated to Mr. Whelan that SilverCrest was interested in exploring a strategic transaction, and suggested that representatives of Coeur and SilverCrest have an initial meeting to discuss their interest in exploring
                a potential transaction. Please expand to provide additional details regarding why Coeur determined to hold an introductory meeting with SilverCrest. Please also provide additional details regarding negotiations and interactions, if any,
                that occurred between you and SilverCrest during the time from the introductory meeting on September 18, 2023 to December 11, 2023 when SilverCrest advised you that it would be interested in exploring a strategic transaction.

      Response:

      In response to the Staff’s comment, the Company has revised the disclosure on pages 60 and 61 of the Amended Preliminary Proxy Statement on Schedule 14A to (i) provide additional details regarding why Coeur determined
        to hold an introductory meeting with SilverCrest and (ii) clarify that the parties did not engage in negotiations or have any significant interactions regarding terms of a business combination during the time from the introductory meeting on
        September 18, 2023 to December 11, 2023.

            2.

              You disclose that on March 25, 2024, Coeur and an intermediate precious metals producer “Party 1” entered into a mutual confidentiality agreement and each began to share confidential information with and
                perform due diligence on the other, and that during the months of March through July 2024, Coeur continued to conduct due diligence on Party 1. You also disclose that on July 15, 2024, Coeur and Party 1 held a mutual information-sharing
                session and following such session, Coeur and Party 1 continued to share confidential information with and perform due diligence on each other. Please revise this section to disclose why and when you determined not to pursue a transaction
                with Party 1.

      Response:

      In response to the Staff’s comment, the Company has revised the disclosure on page 62 of the Amended Preliminary Proxy Statement on Schedule 14A to provide additional details regarding Coeur ceasing negotiations with
        Party 1.

            3.

              We note your disclosure that after Coeur submitted a non-binding indication of interest to SilverCrest on August 2, 2024, SilverCrest delivered a revised indication of interest on August 8, 2024, following the
                close of trading (the “August 8 Indication of Interest”). Please revise to describe the terms of the August 8 Indication of Interest.

      Response:

      In response to the Staff’s comment, the Company has updated the disclosure on pages 62 and 63 of the Amended Preliminary Proxy Statement on Schedule 14A to include the terms of the August 8 Indication of Interest.

            4.

              We note your disclosure that on August 9, 2024, the parties signed the final indication of interest (the "August 9 Indication of Interest"), pursuant to which Coeur and SilverCrest agreed, subject to due
                diligence, to a fixed exchange ratio that implied a spot and 20-day VWAP premium for SilverCrest shares equal to approximately 24% and 17%, respectively, based on the closing share prices as of August 8, 2024. We further note you disclose
                that on September 22-23, 2024, the Coeur Board discussed that the offer consideration set forth in the August 9 Indication of Interest should be adjusted prior to an announcement and the Coeur Board agreed that a 15% premium on the 20-day
                VWAP of SilverCrest was an appropriate target. Lastly, we note you disclose that over the course of October 1, 2024 and October 2, 2024, the parties continued to negotiate the proposed consideration, and the meeting was concluded with an
                alignment by both parties that the proposed consideration under the Arrangement would reflect an implied 18% premium for SilverCrest Common Shares, based on the 20-day VWAPs of Coeur and SilverCrest as of the date of the Arrangement
                Agreement, which was consistent with the premium implied by the proposed consideration set forth in the August 9 Indication of Interest. Please revise the background section to provide the rationale for increasing the proposed consideration
                and premium for the arrangement. Additionally, please expand your disclosure to provide details surrounding negotiations of the Arrangement Agreement.

      Response:

      In response to the Staff’s comment, the Company has updated the disclosure on pages 62 and 63 of the Amended Preliminary Proxy Statement on Schedule 14A to include additional context to the premiums implied by the
        indications of interest and to provide more details surrounding negotiations of the Arrangement Agreement.

            5.

              We note your disclosure on page 76 that in connection with rendering its opinion and performing its related financial analyses, Goldman Sachs reviewed, among other things, certain internal financial analyses
                and forecasts for SilverCrest prepared by its management. Please disclose these forecasts for SilverCrest.

      Response:

      In response to the Staff’s comment, the Company has updated the disclosure on page 83 of the Amended Preliminary Proxy Statement on Schedule 14A to include certain internal financial analyses and forecasts for
        SilverCrest prepared by SilverCrest’s management.

            6.

              We note your references to Cormark in this section. Please expand your disclosure to provide a discussion of Cormark's role in the proposed arrangement and related negotiations.

      Response:

      In response to the Staff’s comment, the Company has updated the disclosure on page 61 of the Amended Preliminary Proxy Statement on Schedule 14A to clarify that Cormark acted as SilverCrest’s financial advisor.

      If we can be of any further assistance, or if you have any questions regarding the concerns detailed in this letter, please do not hesitate to call me at (212) 351-4064.

              Sincerely,

              /s/ Andrew Kaplan

              Andrew Kaplan

            cc:

              Casey Nault

                Coeur Mining, Inc.

                Senior Vice President, General Counsel and

                Chief ESG Officer (Company Secretary)

December 6, 2024
Mitchell J. Krebs
Chief Executive Officer
Coeur Mining, Inc.
200 South Wacker Drive, Suite 2100
Chicago, IL 60606
Re:Coeur Mining, Inc.
Preliminary Proxy Statement on Schedule 14A
Filed November 14, 2024
File No. 001-08641
Dear Mitchell J. Krebs:
            We have reviewed your filing 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.
Preliminary Proxy Statement on Schedule 14A
Background of the Arrangement, page 60
1.We note your disclosure that on September 18, 2023, Mr. Thomas Whelan, Senior
Vice President and Chief Financial Officer of Coeur, who also heads Coeur’s
Corporate Development team, held an introductory meeting with Mr. N. Eric Fier, the
Chief Executive Officer and a director of SilverCrest, and Ms. Tara Hassan, P.Eng,
the Vice President, Corporate Development of SilverCrest. We further note that on
December 11, 2023, a representative of Cormark Securities Inc. indicated to Mr.
Whelan that SilverCrest was interested in exploring a strategic transaction, and
suggested that representatives of Coeur and SilverCrest have an initial meeting to
discuss their interest in exploring a potential transaction. Please expand to provide
additional details regarding why Coeur determined to hold an introductory meeting
with SilverCrest. Please also provide additional details regarding negotiations and
interactions, if any, that occurred between you and SilverCrest during the time from
the introductory meeting on September 18, 2023 to December 11, 2023 when
SilverCrest advised you that it would be interested in exploring a strategic transaction.

December 6, 2024
Page 2
2.You disclose that on March 25, 2024, Coeur and an intermediate precious metals
producer “Party 1” entered into a mutual confidentiality agreement and each began to
share confidential information with and perform due diligence on the other, and that
during the months of March through July 2024, Coeur continued to conduct due
diligence on Party 1. You also disclose that on July 15, 2024, Coeur and Party 1 held a
mutual information-sharing session and following such session, Coeur and Party 1
continued to share confidential information with and perform due diligence on each
other. Please revise this section to disclose why and when you determined not to
pursue a transaction with Party 1.
3.We note your disclosure that after Coeur submitted a non-binding indication of
interest to SilverCrest on August 2, 2024, SilverCrest delivered a revised indication of
interest on August 8, 2024, following the close of trading (the “August 8 Indication of
Interest”). Please revise to describe the terms of the August 8 Indication of Interest.
4.We note your disclosure that on August 9, 2024, the parties signed the final indication
of interest (the "August 9 Indication of Interest"), pursuant to which Coeur and
SilverCrest agreed, subject to due diligence, to a fixed exchange ratio that implied a
spot and 20-day VWAP premium for SilverCrest shares equal to approximately 24%
and 17%, respectively, based on the closing share prices as of August 8, 2024. We
further note you disclose that on September 22-23, 2024, the Coeur Board discussed
that the offer consideration set forth in the August 9 Indication of Interest should be
adjusted prior to an announcement and the Coeur Board agreed that a 15% premium
on the 20-day VWAP of SilverCrest was an appropriate target. Lastly, we note you
disclose that over the course of October 1, 2024 and October 2, 2024, the parties
continued to negotiate the proposed consideration, and the meeting was concluded
with an alignment by both parties that the proposed consideration under the
Arrangement would reflect an implied 18% premium for SilverCrest Common Shares,
based on the 20-day VWAPs of Coeur and SilverCrest as of the date of the
Arrangement Agreement, which was consistent with the premium implied by the
proposed consideration set forth in the August 9 Indication of Interest. Please revise
the background section to provide the rationale for increasing the proposed
consideration and premium for the arrangement. Additionally, please expand your
disclosure to provide details surrounding negotiations of the Arrangement Agreement.
5.We note your disclosure on page 76 that in connection with rendering its opinion and
performing its related financial analyses, Goldman Sachs reviewed, among other
things, certain internal financial analyses and forecasts for SilverCrest prepared by its
management. Please disclose these forecasts for SilverCrest.
6.We note your references to Cormark in this section. Please expand your disclosure to
provide a discussion of Cormark's role in the proposed arrangement and related
negotiations.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.

December 6, 2024
Page 3
            Please contact Cheryl Brown at 202-551-3905 or Irene Barberena-Meissner at 202-
551-6548 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Eric Scarazzo, Esq.

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          Gibson, Dunn & Crutcher LLP

          200 Park Avenue

            New York, NY  10166-0193

          Tel 212.351.4000

          gibsondunn.com

  November 14, 2024

  VIA EDGAR CORRESPONDENCE

  U.S. Securities and Exchange Commission

  100 F Street, N.E.

  Washington, DC 20549

          Re:

          Coeur Mining, Inc. Preliminary Proxy Statement on Schedule 14A

  Ladies and Gentlemen:

  Pursuant to Rule 14a-6(d) of the Securities Exchange Act of 1934, as amended, please be advised that Coeur Mining, Inc. (the “Company”) filed with the Securities and Exchange Commission (the “Commission”) on November 14,
    2024, the Company’s Preliminary Proxy Statement on Schedule 14A (the “Preliminary Proxy Statement”) in connection with the Company’s Special Meeting of Shareholders to be held in connection with the Arrangement Agreement the Company entered into with
    SilverCrest Metals Inc. on October 3, 2024.  The Company intends to file the Definitive Proxy Statement with the Commission as soon as possible.

  Please direct any questions or comments regarding this filing to the undersigned at (212) 351-4064 or by email at akaplan@gibsondunn.com.

  Sincerely,

  /s/ Andrew Kaplan

  Andrew Kaplan

          Abu Dhabi • Beijing • Brussels • Century City • Dallas • Denver • Dubai • Frankfurt • Hong Kong • Houston • London • Los Angeles

            Munich • New York • Orange County • Palo Alto • Paris • Riyadh • San Francisco • Singapore • Washington, D.C.

United States securities and exchange commission logo
October 17, 2022
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, IL 60603
Re:Coeur Mining, Inc.
Definitive Proxy Statement on Schedule 14A
Filed March 30, 2022
File No. 001-08641
Dear Thomas S. Whelan:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Disclosure Review Program

CORRESP
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Document

September 9, 2022

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-0405

Re:   Coeur Mining, Inc.

Definitive Proxy Statement on Schedule 14A

Filed March 30, 2022

File No. 001-08641

Dear Mr. Dunham and Ms. Ravitz:

On behalf of Coeur Mining, Inc. (the “Company”), this responds to your September 2, 2022 letter regarding our Definitive Proxy Statement on Schedule 14A filed on March 30, 2022.

The Company confirms that it will enhance its future proxy disclosures in accordance with the topics discussed in your letter, to the extent applicable and responsive to Item 407(h) of Regulation S-K.

Very truly yours,

/s/  Thomas S. Whelan

Thomas S. Whelan

Senior Vice President and

Chief Financial Officer

Coeur Mining, Inc.

cc:  Mitchell J. Krebs, President and Chief Executive Officer

      Casey M. Nault, Senior Vice President, General Counsel & Chief ESG Officer

Coeur Mining, Inc., 104 S. Michigan Avenue, Suite 900, Chicago, Illinois 60603

United States securities and exchange commission logo
September 2, 2022
Thomas S. Whelan
Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, IL 60603
Re:Coeur Mining, Inc.
Definitive Proxy Statement on Schedule 14A
Filed March 30, 2022
File No. 001-08641
Dear Mr. Whelan:
            We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comments.
            Please respond to these comments by confirming that you will enhance your future proxy
disclosures in accordance with the topics discussed below as well as any material developments
to your risk oversight structure. For guidance, refer to Item 407(h) of Regulation S-K.
Definitive Proxy Statement on Schedule 14A filed March 30, 2022
General
1.Please expand your discussion of the reasons you believe that your leadership structure is
appropriate, addressing your specific characteristics or circumstances. In your discussion,
please also address the circumstances under which you would consider having the Chair
and CEO roles filled by a single individual, when shareholders would be notified of any
such change, and whether you will seek prior input from shareholders.
2.Please expand upon the role that your Independent Chair plays in the leadership of the
board. For example, please enhance your disclosure to address whether or not your
Independent Chair may:

•represent the board in communications with shareholders and other stakeholders;
•require board consideration of, and/or override your CEO on, any risk matters; or
•provide input on design of the board itself.

 FirstName LastNameThomas S. Whelan
 Comapany NameCoeur Mining, Inc.
 September 2, 2022 Page 2
 FirstName LastName
Thomas S. Whelan
Coeur Mining, Inc.
September 2, 2022
Page 2
3.Please expand upon how your board administers its risk oversight function. For example,
please disclose:

•why your board elected to retain direct oversight responsibility for certain risks rather
than assign oversight to a board committee;
•the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or
long-term) and how you apply different oversight standards based upon the
immediacy of the risk assessed;
•whether you consult with outside advisors and experts to anticipate future threats and
trends, and how often you re-assess your risk environment;
•how the board interacts with management to address existing risks and identify
significant emerging risks;
•whether you have a Chief Compliance Officer and to whom this position reports; and
•how your risk oversight process aligns with your disclosure controls and procedures.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Christopher Dunham at (202) 551-3783 or Amanda Ravitz at (202) 551-
3412 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program

November 1, 2018
Peter Mitchell
Senior Vice President and Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave. Suite 900
Chicago, IL 60603
Re:Coeur Mining, Inc.
Form 10-K
Filed February 7, 2018
File No. 001-08641
Dear Mr. Mitchell:
            We have completed our review of your filing.  We remind you that the company and its
management are responsible for the accuracy and adequacy of their disclosures, notwithstanding
any review, comments, action or absence of action by the staff.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining

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		Document

October 23, 2018

VIA EDGAR

Ms. Pam Howell

Mr. George K. Schuler

Division of Beverages, Apparel and Mining

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:        Coeur Mining, Inc.

Form 10-K filed February 7, 2018 for the year ended December 31, 2017

File No. 001-08641

Dear Ms. Howell and Mr. Schuler:

On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated October 12, 2018 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10‑K for the year ended December 31, 2017 (the “Annual Report”), filed with the Securities and Exchange Commission (the “Commission”) on February 7, 2018.  Each comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the Company’s response.  For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.  The response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

Annual Report on Form 10-K for the Year ended December 31, 2017

Item 2. Properties

Proven and Probable Reserves, page 30

1.

 Mineralized materials are disclosed for your Silvertip property. Please forward to our engineer as supplemental information and not as part of your filing, your information that establishes the quantity and quality of your mineralized materials, as required by Industry Guide 7(c). The information requested includes, but is not limited to:  property and geologic maps; description of your sampling and assaying procedures; drill-hole maps showing drill intercepts; representative geologic cross-sections and drill logs; description and examples of your cut-off calculation procedures; cutoff grades used for each category of your reserves and resources; justifications for the drill hole spacing used to classify and segregate proven

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

and probable reserves; a detailed description of your procedures for estimating reserves; copies of any pertinent engineering or geological reports, and executive summaries of feasibility studies or mine plans which include the cash flow analyses; and a detailed permitting and governmental approval schedule for the project, particularly identifying the primary environmental or construction approval(s) and your current location on that schedule.

As supplemental information, and not part of this letter, the Company has sent an Adobe PDF copy of the “NI43-101 Technical Report Resource Update on the Silvertip Property, Northern British Columbia, Canada for Silvercorp Metals Inc.”, dated February 19, 2010 and available on SEDAR (the “Technical Report”), on a USB “flash drive” to the Commission to the attention of Mr. George K. Schuler.

In connection with the Company’s acquisition of Silvertip, it reviewed the Technical Report, and the associated technical model and supporting data, which was completed by a Qualified Person for Silvercorp Metals, Inc., and the Company deemed it to be valid and compliant mineralized material. Accordingly, the Company determined to include the Silvertip mineralized material included in the Technical Report and associated technical model as part of the Company’s mineralized material at year-end 2017 (with the exception of the gold mineralized material at Silvertip included in the Technical Report, as gold grades were below payable levels for lead or zinc smelters). The Company maintained the cut-off grade of 200 g/t AgEq, even though there were significant improvements to metal prices since the date of the Technical Report.  The mineralized material in the Technical Report assumed a lead price of $0.75/lb, a zinc price of $0.75/lb and a silver price of 12.13/oz ($0.39/g). For the Company’s mineralized material effective December 31, 2017 at Silvertip, assumed metal prices were $20.00/oz for silver, $1.15/lb for zinc and $1.00/lb for lead.

Please contact Chris Pascoe, the Company’s Director, Technical Services Operations, at (312) 489-5842 with any technical questions.

Mineralized Material, page 32

2.

 We note your disclosure of mineralized materials, which appear to be the sum of your measured, indicated, and inferred resources as indicated by a comparison of your filing to your website and technical reports. Mineralized material does not include the tonnage and grade estimated by using geologic inference, which are sometimes classified as “inferred” or “possible” by some evaluators. Please restate your mineralized materials without the inferred resources.

The Company inadvertently included inferred materials in its disclosure of mineralized material in the Annual Report. The disclosure of mineralized material was corrected in the Company’s Quarterly Report on Form 10-Q for the quarter ended March 31, 2018 to exclude inferred tonnage in accordance with Industry Guide 7. That table is copied below. The Company confirms that it will disclose mineralized material for its mines without including “inferred” tonnage in future filings with the Commission.

We would be pleased to address any further Staff comments or questions related to the above matters. If the Staff wishes to discuss this letter at any time, please do not hesitate to contact Casey Nault, Senior Vice President, General Counsel and Secretary at (312) 489-5846 or Ken Watkinson, Vice President, Corporate Controller and Chief Accounting Officer at (312) 489-5870.

Very truly yours,

/s/ PETER C. MITCHELL

Peter C. Mitchell

Senior Vice President and Chief Financial Officer

cc:

 Casey M. Nault, Senior Vice President, General Counsel and Secretary

Ken Watkinson, Vice President, Corporate Controller and Chief Accounting Officer

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

October 12, 2018
Peter Mitchell
Senior Vice President and Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave. Suite 900
Chicago, IL 60603
Re:Coeur Mining, Inc.
Form 10-K
Filed February 7, 2018
File No. 001-08641
Dear Mr. Mitchell:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
FORM 10-K
Proven and Probable Reserves, page 30
1.Mineralized materials are disclosed for your Silvertip property.  Please forward to our
engineer as supplemental information and not as part of your filing, your information that
establishes the quantity and quality of your mineralized materials, as required by Industry
Guide 7(c).  The information requested includes, but is not limited to:

•Property and geologic maps

•Description of your sampling and assaying procedures

•Drill-hole maps showing drill intercepts

 FirstName LastNamePeter Mitchell
 Comapany NameCoeur Mining, Inc.
 October 12, 2018 Page 2
 FirstName LastNamePeter Mitchell
Coeur Mining, Inc.
October 12, 2018
Page 2

•Representative geologic cross-sections and drill logs

•Description and examples of your cut-off calculation procedures

•Cutoff grades used for each category of your reserves and resources

•Justifications for the drill hole spacing used to classify and segregate proven and
probable reserves

•A detailed description of your procedures for estimating reserves

•Copies of any pertinent engineering or geological reports, and executive summaries of
feasibility studies or mine plans which including the cash flow analyses

•A detailed permitting and government approval schedule for the project, particularly
identifying the primary environmental or construction approval(s) and your current
location on that schedule.

To minimize the transfer of paper, please provide the requested information on a CD or a
flash drive, formatted as Adobe PDF files and provide the name and phone number for a
technical person our engineer may call, if he has technical questions about your reserves.

In the event your company desires the return of this supplemental material, please make a
written request with the letter of transmittal and include a pre-paid, pre-addressed shipping
label to facilitate the return of the supplemental information.  Please note that you may
request the return of this information pursuant to the provisions of Rule 12b-4 of the
Exchange Act.

If there are any questions concerning the above request, please phone Mr. George K.
Schuler, Mining Engineer at (202) 551-3718.

Mineralized Material, page 32
2.We note your disclosure of mineralized materials, which appear to be the sum of your
measured, indicated, and inferred resources as indicated by a comparison of your filing to
your website and technical reports.  Mineralized material does not include the tonnage and
grade estimated by using geologic inference, which are sometimes classed as “inferred” or
“possible” by some evaluators.  Please restate your mineralized materials without the
inferred resources.

 FirstName LastNamePeter Mitchell
 Comapany NameCoeur Mining, Inc.
 October 12, 2018 Page 3
 FirstName LastName
Peter Mitchell
Coeur Mining, Inc.
October 12, 2018
Page 3
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact George K. Schuler at (202) 551-3718 or Pam Howell at (202) 551-3357
with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining

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VIA EDGAR

August 1, 2017

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re:

Coeur Mining, Inc.

Registration Statement on Form S-4 (File No. 333-219492)

Ladies and Gentlemen:

This letter is sent on behalf of Coeur Mining, Inc. (the “Company”) and the co-registrant subsidiaries of the Company in connection with the above-referenced Registration Statement on Form S-4 (the “Registration Statement”) filed with the Securities and Exchange Commission (the “Commission”) by the Company and co-registrants pursuant to the Securities Act of 1933, as amended (the “Securities Act”).  Pursuant to Rule 461 promulgated under the Securities Act, the Company, on behalf of itself and the co-registrants, hereby respectfully requests that the effective time of the Registration Statement be accelerated to 4:00 p.m., Eastern Time, on August 3, 2017 or as soon as practicable thereafter.

Very truly yours,

/s/ Casey M. Nault

Casey M. Nault

Senior Vice President, General Counsel and

Secretary

Coeur Mining, Inc.

cc:          Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois l 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

Mail Stop 3561
July 31, 2017

Via E -mail
Casey M. Nault
General Counsel and Secretary
Coeur Mining, Inc.
104 S. Michigan Avenue, Suite 900
Chicago, Illinois 60603

Re: Coeur Mining, Inc.
  Registration Statement on Form S-4
Filed  July 27, 2017
  File No.  333-219492

Dear Mr. Nault :

This is to advise you that we have not  reviewed and will not review your registration
statement .

Please refer to Rules 460 and 461 regarding requests for acceleration.  We remind you
that the company and its management are responsible for the accuracy and adequacy of their
disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please  contact Michael Killoy  at (202) 551 -7576  with any questions.

Sincerely,

 /s/ Brigitte Lippmann (for)

 John Reynolds
Assistant Director
Office of Beverages, Apparel
and Mining

cc: Andrew L. Fabens
 Gibson, Dunn & Crutcher LLP

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July 26, 2017

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Coeur Mining, Inc. Registration Statement on Form S-4

Ladies and Gentlemen:

This letter is sent on behalf of Coeur Mining, Inc. (the “Company”) and certain subsidiary guarantors of the Company (the “Guarantors”) in connection with a Registration Statement on Form S-4 (the “Registration Statement”) filed with the Securities and Exchange Commission (the “Commission”) by the Company and Guarantors pursuant to the Securities Act of 1933, as amended (the “Securities Act”), relating to the proposed offer to exchange (the “Exchange Offer”) up to $250,000,000 principal amount of its new 5.875% Senior Notes due 2024 (the “New Notes”) and guarantees thereof by the Guarantors for a like principal amount of the Company’s outstanding 5.875% Senior Notes due 2024 (the “Outstanding Notes”) and guarantees thereof by the Guarantors.

The Company and the Guarantors are registering the Exchange Offer pursuant to the Registration Statement in reliance on the position enunciated by the staff of the Commission (the “Staff”) in Exxon Capital Holdings Corp., SEC No-Action Letter available May 13, 1988, Morgan Stanley & Co., SEC No-Action Letter available June 5, 1991, and Shearman & Sterling, SEC No-Action Letter available July 2, 1993.  Neither the Company nor the Guarantors has entered into any arrangement or understanding with any person to distribute the New Notes to be received in the Exchange Offer and, to the best of the Company’s and each Guarantor’s information and belief, each person participating in the Exchange Offer will be acquiring the New Notes in its ordinary course of business and has no arrangement or understanding with any person to participate in the distribution of the New Notes to be received in the Exchange Offer.  In this regard, the Company will make each person participating in the Exchange Offer aware (through the Exchange Offer prospectus) that any person using the Exchange Offer to participate in a distribution of the New Notes to be received in the Exchange Offer (1) cannot rely on the Staff’s position enunciated in the Exxon Capital SEC No-Action Letter or similar letters of the Staff and (2) must comply with registration and prospectus delivery requirements of the Securities Act in connection with any secondary resale transaction.  The Company acknowledges that such a secondary resale transaction should be covered by an effective registration statement containing the selling securityholder information required by Item 507 of Regulation SK.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois l 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

The Company will include in the transmittal letter or similar documentation to be executed by an Exchange Offer offeree in order to participate in the Exchange Offer a provision equivalent to the following:

If the Exchange Offer offeree is a broker-dealer that will receive New Notes for its own account in exchange for Outstanding Notes that were acquired as a result of market-making activities or other trading activities, it acknowledges that it will deliver a prospectus in connection with any resale of such New Notes; however, by so acknowledging and by delivering a prospectus, a broker-dealer will not be deemed to admit that it is an “underwriter” within the meaning of the Securities Act.

The Company will also require that each participant in the Exchange Offer furnish a representation in the transmittal letter or similar documentation that neither such participant nor, to the actual knowledge of such participant, any other person receiving New Notes from such participant, has any arrangement or understanding with any person to participate in the distribution of the New Notes.

The Company will make broker-dealers participating in the Exchange Offer aware (through the Exchange Offer prospectus) that any broker-dealer that resells New Notes that were received by it for its own account pursuant to the Exchange Offer and any broker or dealer that participates in a distribution of such New Notes may be deemed to be an “underwriter” within the meaning of the Securities Act and must deliver a prospectus meeting the requirements of the Securities Act in connection with any resale of such New Notes.

Please do not hesitate to contact Andrew L. Fabens of Gibson, Dunn & Crutcher LLP at (212) 351-4034 or the undersigned at (312) 489-5846 with any questions or comments concerning this letter.

[Signature page follows.]

2

Kind regards,

/s/ Casey M. Nault

Casey M. Nault

Senior Vice President, General Counsel and Secretary Coeur Mining, Inc.

cc:

Andrew L. Fabens,

Gibson, Dunn & Crutcher LLP

Mail Stop 3561       December 14, 2016

Via Email
Mr. Peter C. Mitchell
Senior Vice President and Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave.
Suite 900
Chicago IL 60603

Re: Coeur Mining, Inc.
Form 10 -K for the year ended December 31, 2015
Filed February 10, 2016
File No. 1-08641

Dear Mr. Mitchell :

We have completed our review of your filing s.  We remind you that the company and its
management are responsible for the accuracy and adequacy of the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Joel Parker

Joel Parker
Senior Assistant Chief Accountant
Office of Beverages, Apparel and
Mining

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		Document

December 6, 2016

VIA EDGAR AND HAND DELIVERY

Mr. Joel Parker

Senior Assistant Chief Accountant

Office of Beverages, Apparel and Mining

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:        Coeur Mining, Inc.

Form 10-Q for the quarter ended June 30, 2016

Response Dated November 4, 2016

File No. 1-08641

Dear Mr. Parker:

On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated November 23, 2016 (the “Comment Letter”), regarding the above-referenced Quarterly Report on Form 10‑Q for the quarter ended June 30, 2016 (the “Quarterly Report”), filed with the Securities and Exchange Commission (the “Commission”) on July 27, 2016.  The comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the response.  For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.  The response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

Quarterly Report on Form 10-Q for the Quarter ended June 30, 2016

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Non-GAAP Financial Performance Measures, page 41

1.

 Your response to comment 3 and your proposed disclosure indicates that the tax impact of adjustments are generally determined based on statutory tax rates and the related jurisdictional tax attributes, including the impact through the Company’s valuation allowance. However, your proposed disclosure does not clearly explain in any detail how the tax effect of the adjustments for each period presented in your 10-Q were determined. Please revise to clearly explain how the tax effect of your adjustments to net income to arrive at adjusted net income for each period presented were calculated or determined.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

The Company will revise future filings to clearly explain how the tax effect of adjustments to net income to arrive at adjusted income were calculated. An example of the disclosure that will be included in the Company’s future filings is as follows:

Adjusted Net Income (Loss)

Management uses Adjusted net income (loss) to evaluate the Company's operating performance, and to plan and forecast its operations.  The Company believes the use of Adjusted net income (loss) reflects the underlying operating performance of our core mining business and allows investors and analysts to compare results of the Company to similar results of other mining companies.  Management's determination of the components of Adjusted net income (loss) are evaluated periodically and are based, in part, on a review of non-GAAP financial measures used by mining industry analysts.  The tax effect of adjustments are based on statutory tax rates and the Company’s tax attributes, including the impact through the Company’s valuation allowance. The combined effective rate of tax adjustments may not be consistent with statutory tax rates or the Company’s effective tax rate due to jurisdictional tax attributes and related valuation allowance impacts which may minimize the tax effect of certain adjustments and may not apply to gains and losses equally. Adjusted net income (loss) is reconciled to Net income (loss) in the table below:

 Three months ended June 30,

 Six months ended June 30,

In thousands except per share amounts

 2016

 2015

 2016

 2015

Net income (loss)

 $

 14,497

 $

 (16,677

 )

 $

 (5,899

 )

 $

 (49,965

 )

Fair value adjustments

 3,579

 (2,754

 )

 12,274

 2,130

Impairment of marketable securities

 20

 31

 20

 1,545

Write-downs

 —

 —

 4,446

 —

Gain on sale of assets

 (2,812

 )

 (107

 )

 (4,486

 )

 (63

 )

(Gain) loss on debt extinguishments

 —

 524

 —

 271

Transaction-related costs

 792

 38

 1,172

 2,013

Tax effect of adjustments(1)

 3,996

 136

 2,621

 (409

 )

Foreign exchange (gain) loss

 (2,810

 )

 751

 (3,933

 )

 2,028

Adjusted net income (loss)

 $

 17,262

 $

 (18,058

 )

 $

 6,215

 $

 (42,450

 )

Adjusted net income (loss) per share

 $

 0.11

 $

 (0.13

 )

 $

 0.04

 $

 (0.36

 )

(1)

 For the three months ended June 2016, tax effect of adjustments of $3,996 (-253%) is primarily related to a taxable gain on the sale of an asset, partially offset by losses on other asset sales where no tax benefit was recognized and tax benefit from fair value adjustments. For the three months ended June 30, 2015, tax effect of adjustments of $136 (6%) is tax expense from fair value adjustments.

For the six months ended June 30, 2016, tax effect of adjustments of $2,621 (-20%) is primarily related to a taxable gain on the sale of assets and the tax valuation allowance impact from an asset write-down, partially offset by tax benefit from fair value adjustments. For the six months ended June 30, 2015, tax effect of adjustments of $(409) (7%) for the six months ended June 30, 2015 is tax benefit from fair value adjustments.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

We would be pleased to address any further Staff comments or questions related to the above matters. If the Staff wishes to discuss this letter at any time, please do not hesitate to contact Casey Nault, Senior Vice President, General Counsel and Secretary at (312) 489-5846 or Mark Spurbeck, Vice President, Finance at (312) 489-5863.

Very truly yours,

/s/ PETER C. MITCHELL

Peter C. Mitchell

Senior Vice President and Chief Financial Officer

cc:

 Casey M. Nault, Senior Vice President, General Counsel and Secretary

Mark Spurbeck, Vice President, Finance

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

Mail Stop 3561
November 23, 2016

Via Email
Mr. Peter C. Mitchell
Senior Vice President and Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave.
Suite 900
Chicago IL 60603

Re: Coeur Mining, Inc.
 Form 10-Q for the quarter ended June 30, 2016
Response Dated November 4, 2016
File No.  1 -08641

Dear Mr. Mitchell:

We have reviewed your November 4, 2016 response to our comment letter  and have the
following comments.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional
comments.   Unless we n ote otherwise, our references to prior comments are to comments in our
October 25, 2016 letter.

Quarterly Report on Form 10 -Q for the Quarter ended June 30, 2016
Item 2. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Performance Measures, page 41

1. Your response to comment 3 and your proposed disclosure indicates that the tax impact
of adjustments are generally determined based on statutory tax rates and the related
jurisdictional tax attr ibutes, including the impact through the Company’s valuation
allowance.  However, your proposed disclosure does not clearly explain in any detail how
the tax effect of the adjustment s for each period presented in your 10 -Q were determined.
Please revise to clearly explain how the tax effect of your adjustments to net income to
arrive at adjusted net income for each period presented were calculated or determined.

Mr. Peter C. Mitchell
Coeur Mining, Inc.
November 23 , 2016
Page 2

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Linda Cvrkel, Staff Accountant  at (202) 551 -3813  or me at (202) 551 -
3651  if you have questions regarding comments on the financial stat ements and related matters
or for any other questions.

Sincerely,

 /s/ Joel Parker

Joel Parker
Senior Assistant Chief Accountant
Office of Beverages, Apparel and
Mining

CORRESP
1
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		Document

November 4, 2016

VIA EDGAR AND HAND DELIVERY

Mr. Joel Parker

Senior Assistant Chief Accountant

Office of Beverages, Apparel and Mining

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:        Coeur Mining, Inc.

Form 10-K

Filed February 10, 2016

File No. 1-08641

Dear Mr. Parker:

On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated October 25, 2016 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10‑K for the year ended December 31, 2015 (the “Annual Report”), filed with the Securities and Exchange Commission (the “Commission”) on February 10, 2016.  Each comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the corresponding response.  For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.  Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

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

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

Consolidated Financial Results

2015 Compared to 2014

Income and Mining Taxes, page 38

1.

 Your discussion on page 38 of MD&A indicates that your effective tax rate was 6.7% in 2015 as compared to an effective tax rate of 26.5% for 2014.  Your discussion also indicates that the effective tax rate is impacted by recurring items such as foreign exchange rates on deferred tax balances, the impacts of mineral interest impairments, the full valuation allowance on the deferred tax assets in the United States and certain foreign jurisdictions, mining tax expense and uncertain tax position accruals.  However, you provide no discussion or insight into the specific factors or circumstances that caused your effective tax rate to

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

decline from 26.5% in 2014 to 6.7% in 2015.  Please revise future filings to provide a discussion of the specific facts or circumstances that resulted in this significant change in your effective tax rate.  Please provide your proposed disclosure as part of your response.

The Company confirms it will include in MD&A a tax rate reconciliation and provide discussion of specific facts or circumstances that result in significant changes in our effective tax rate in future annual filings.   An example of the disclosure that will be included in our future Annual Report is as follows:

Income and Mining Taxes

The Company’s Income and mining tax benefit (expense) consisted of:

 Year ended December 31,

In thousands

 2015

 2014

Income and mining tax benefit (expense) at statutory rate

 $

 137,706

 $

 565,295

State tax provision from continuing operations

 (2,075

 )

 20,253

Change in valuation allowance

 (101,027

 )

 (151,191

 )

Uncertain tax positions

 (1,947

 )

 (4,425

 )

U.S. and foreign non-deductible expenses

 1,365

 (4,892

 )

Mineral interest related

 (19,310

 )

 —

Foreign exchange rates

 22,350

 23,672

Foreign inflation and indexing

 1,117

 3,765

Foreign tax rate differences

 (15,980

 )

 (63,930

 )

Foreign withholding and other taxes

 8,140

 82,884

Foreign tax credits and other, net

 (4,076

 )

 (43,177

 )

Income and mining tax benefit (expense)

 $

 26,263

 $

 428,254

Income and mining tax benefit of approximately $26.3 million results in an effective tax rate of 6.7% for 2015. This compares to income tax benefit of $428.3 million or effective tax rate of 26.5% for 2014. The Company’s effective tax rate is impacted by multiple factors as illustrated above. The 2015 effective tax rate differs from 2014 primarily due to changes in valuation allowances on deferred tax assets, including the impacts of mineral interest impairments, and lower foreign withholding taxes.

The Company’s effective tax rate is impacted by recurring items, such as foreign exchange rates on deferred tax balances, impacts of mineral interest impairments, full valuation allowance on the deferred tax assets relating to losses in the United States and certain foreign jurisdictions, mining tax expense and uncertain tax positions.  In addition, the Company's consolidated effective income tax rate is a function of the combined effective tax rates and foreign exchange rates in the jurisdictions in which it operates.  Variations in the jurisdictional mix of income and loss and foreign exchange rates result in significant fluctuations in its consolidated effective tax rate.  The following table summarizes the components of the Company’s income (loss) before tax and income and mining tax (expense) benefit:

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

 Year ended December 31, 2015

 Year ended December 31, 2014

In thousands

 Income (loss) before tax

 Tax (expense) benefit

 Income (loss) before tax

 Tax (expense) benefit

United States

 $

 (43,924

 )

 $

 (527

 )

 $

 (213,883

 )

 $

 (482

 )

Argentina

 (3,869

 )

 (482

 )

 (82,093

 )

 24,408

Mexico

 (250,054

 )

 26,713

 (1,204,983

 )

 384,099

Bolivia

 (76,739

 )

 (5,154

 )

 (107,547

 )

 18,114

Other jurisdictions

 (18,860

 )

 5,713

 (6,622

 )

 2,115

 $

 (393,446

 )

 $

 26,263

 $

 (1,615,128

 )

 $

 428,254

A valuation allowance is provided for deferred tax assets for which it is more likely than not that the related benefits will not be realized.  The Company analyzes its deferred tax assets and if it is determined that the Company will not realize all or a portion of its deferred tax assets, it will record or increase a valuation allowance.  Conversely, if it is determined that the Company will ultimately be able to realize all or a portion of the related benefits for which a valuation allowance has been provided, all or a portion of the related valuation allowance will be reduced.  There are a number of risk factors that could impact the Company’s ability to realize its deferred tax assets.

Item 8. Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

Note 20 - Supplemental Guarantor Information, page 86

2.

 Your disclosure in Note 20 indicates that each of your subsidiary guarantors is 100% owned by Coeur and the guarantees are full and unconditional.  Please revise future filings to also disclose whether the guarantees are joint and several.  Refer to the requirements outlined in Rule 3-10(f) of Regulation S-X.

The Company confirms it will revise future filings to disclose that the subsidiary guarantees are joint and several.  An example of the disclosure that will be included in the Company’s future filings is as follows:

NOTE 19 - SUPPLEMENTAL GUARANTOR INFORMATION

The following Condensed Consolidating Financial Statements are presented to satisfy disclosure requirements of Rule 3-10 of Regulation S-X resulting from the guarantees by Coeur Alaska, Inc., Coeur Explorations, Inc., Coeur Rochester, Inc., Coeur South America Corp., Wharf Resources (U.S.A.), Inc. and its subsidiaries, and Coeur Capital, Inc. (collectively, the “Subsidiary Guarantors”) of the Senior Notes.  The following schedules present Condensed Consolidating Financial Statements of (a) Coeur, the parent company; (b) the Subsidiary Guarantors; and (c) certain wholly-owned domestic and foreign subsidiaries of the Company (collectively, the “Non-Guarantor Subsidiaries”). Each of the Subsidiary Guarantors is 100% owned by Coeur and the guarantees are full and unconditional and joint and several obligations. There are no restrictions on the ability of Coeur to obtain funds from the Subsidiary Guarantors by dividend or loan.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

Quarterly Report on Form 10-Q for the Quarter ended June 30, 2016

Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Non-GAAP Financial Performance Measures, page 41

3.

 In your reconciliation of net income (loss) to the non-GAAP measure, adjusted net income (loss), you reflect a reconciling adjustment for the tax effect of adjustments.  Please revise to explain how you calculated or determined the tax effect of adjustments.  Refer to the guidance in Question 102.11 of the updated Compliance and Disclosure Interpretations issued on May 17, 2016.

The Company confirms it will revise future filings to disclose how the Company calculates the tax effects of adjustments to net income.  An example of the disclosure that will be included in the Company’s future filings is as follows:

Adjusted Net Income (Loss)

Management uses Adjusted net income (loss) to evaluate the Company's operating performance, and to plan and forecast its operations.  The Company believes the use of Adjusted net income (loss) reflects the underlying operating performance of our core mining business and allows investors and analysts to compare results of the Company to similar results of other mining companies.  Management's determination of the components of Adjusted net income (loss) are evaluated periodically and are based, in part, on a review of non-GAAP financial measures used by mining industry analysts.  Tax impacts of adjustments are generally determined based on statutory tax rates and related jurisdictional tax attributes, including the impact through the Company’s valuation allowance.  Adjusted net income (loss) is reconciled to Net income (loss) in the table below:

 Three months ended June 30,

 Six months ended June 30,

In thousands except per share amounts

 2016

 2015

 2016

 2015

Net income (loss)

 $

 14,497

 $

 (16,677

 )

 $

 (5,899

 )

 $

 (49,965

 )

Fair value adjustments

 3,579

 (2,754

 )

 12,274

 2,130

Impairment of marketable securities

 20

 31

 20

 1,545

Write-downs

 —

 —

 4,446

 —

Gain on sale of assets

 (2,812

 )

 (107

 )

 (4,486

 )

 (63

 )

(Gain) loss on debt extinguishments

 —

 524

 —

 271

Transaction-related costs

 792

 38

 1,172

 2,013

Tax effect of adjustments

 3,996

 136

 2,621

 (409

 )

Foreign exchange (gain) loss

 (2,810

 )

 751

 (3,933

 )

 2,028

Adjusted net income (loss)

 $

 17,262

 $

 (18,058

 )

 $

 6,215

 $

 (42,450

 )

Adjusted net income (loss) per share

 $

 0.11

 $

 (0.13

 )

 $

 0.04

 $

 (0.36

 )

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

We would be pleased to address any further Staff comments or questions related to the above matters. If the Staff wishes to discuss this letter at any time, please do not hesitate to contact Casey Nault, Senior Vice President, General Counsel and Secretary at (312) 489-5846 or Mark Spurbeck, Vice President, Finance at (312) 489-5863.

Very truly yours,

/s/ PETER C. MITCHELL

Peter C. Mitchell

Senior Vice President and Chief Financial Officer

cc:

 Casey M. Nault, Senior Vice President, General Counsel and Secretary

Mark Spurbeck, Vice President, Finance

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

Mail Stop 3561
October 25 , 2016

Via Email
Mr. Peter C. Mitchell
Senior Vice President and Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave.
Suite 900
Chicago IL 60603

Re: Coeur Mining, Inc.
 Form 10-K
Filed February 10, 2016
File No.  1 -08641

Dear Mr. Mitchell:

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

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circum stances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for the Year Ended December 31, 2015
Item 7. Management’s Discussion and Analysis of Financial Condit ion and Results of
Operations
Consolidated Financial Results
2015 Compared to 2014
Income and Mining Taxes, page 38

1. Your discussion on page 38 of MD&A indicates that your effective tax rate was 6.7% in
2015 as compared to an effective tax rate of 26.5% fo r 2014.  Your discussion also
indicates that the effective tax rate is impacted by recurring items such as foreign
exchange rates on deferred tax balances, the impacts of mineral interest impairments, the
full valuation allowance on the deferred tax assets  in the United States and certain foreign
jurisdictions, mining tax expense and uncertain tax position accruals.  However, you
provide no discussion or insight into the specific factors or circumstances that caused
your effective tax rate to decline from 2 6.5% in 2014 to 6.7% in 2015.  Please revise

Mr. Peter C. Mitchell
Coeur Mining, Inc.
October 25 , 2016
Page 2

 future filings to provide a discussion of the specific facts or circumstances that resulted in
this significant change in your effective tax rate.  Please provide your proposed disclosure
as part of your respons e.

Item 8. Financial Statements and Supplementary Data
Notes to Consolidated Financial Statements
Note 20 – Supplemental Guarantor Information, page 86

2. Your disclosure in Note 20 indicates that each of your subsidiary guarantors is 100%
owned by Coeur an d the guarantees are full and unconditional.  Please revise future
filings to also disclose whether the guarantees are joint and several.  Refer to the
requirements outlined in Rule 3 -10(f) of Regulation S -X.

Quarterly Report on Form 10 -Q for the Quarter ended June 30, 2016
Item 2. Management’s Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Performance Measures, page 41

3. In your reconciliation of net income (loss) to the non -GAAP measure, adjusted net
income (lo ss), you reflect a reconciling adjustment for the tax effect of adjustments.
Please revise to explain how you calculated or determined the tax effect of adjustments.
Refer to the guidance in Question 102.11 of  the updated Compliance and Disclosure
Interpretations  issued on May 17, 2016.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disc losures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Linda Cvrkel, Staff Accountant  at (202) 551 -3813  or me at (202) 551 -
3651  if you have questions regarding comments on the financial stat ements and re lated matters
or for any other questions.

Sincerely,

 /s/ Joel Parker

Joel Parker
Senior Assistant Chief Accountant
Office of Beverages, Apparel and
Mining

CORRESP
1
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Correspondence

 Coeur Mining, Inc.

 104 S.
Michigan Ave., Suite 900

 Chicago, Illinois 60603

March 16, 2015

 VIA EDGAR CORRESPONDENCE

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street, N.E.

 Washington, D.C.
20549

Attention:

Mr. John Reynolds, Assistant Director

Ms. Pamela Howell

Ms. Hillary Daniels

Re:
Coeur Mining, Inc.

 Registration Statement on Form S-4 (File No. 333-201382)

 Dear Mr. Reynolds, Ms. Howell and Ms. Daniels:

This letter is sent on behalf of Coeur Mining, Inc. (the “Company”) in connection with the above-referenced Registration
Statement on Form S-4 (the “Registration Statement”) filed with the Securities and Exchange Commission (the “Commission”) by the Company pursuant to the Securities Act of 1933, as amended (the “Securities
Act”). Pursuant to Rule 461 promulgated under the Securities Act, the Company hereby requests that the effective date of the Registration Statement be accelerated to 5:30 p.m., New York City time, on March 16, 2015, or as soon
thereafter as practicable.

 The Company hereby acknowledges that:

•

should the Commission or the staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
Statement;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,

COEUR MINING, INC.

By:

 /s/ Casey M. Nault

Name:

Casey M. Nault

Title:

Senior Vice President, General Counsel and Secretary

cc:
Steven R. Shoemate, Gibson, Dunn & Crutcher LLP

 2

CORRESP
1
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CORRESP

Gibson, Dunn & Crutcher LLP

200 Park Avenue

 New York,
NY 10166-0193

 Tel 212.351.4000

www.gibsondunn.com

 March 13, 2015

 VIA
EDGAR CORRESPONDENCE

 United States Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549

Attention:

Mr. John Reynolds, Assistant Director

Ms. Pamela Howell

Ms. Hillary Daniels

Re:
Response to SEC Staff Comment Letter dated March 11, 2015

 Coeur Mining, Inc.

 Amendment No. 2 to Registration Statement on Form S-4

Filed March 4, 2015

File No. 333-201382

 Dear
Mr. Reynolds, Ms. Howell and Ms. Daniels:

 On behalf of Coeur Mining, Inc. (“Coeur”), this letter responds to
your letter, dated March 11, 2015 (the “Comment Letter”), regarding the above referenced filing (as amended from time to time, the “Registration Statement”) relating to the proposed acquisition of Paramount Gold and Silver
Corp. (“Paramount”) by Coeur. As we discussed with Ms. Daniels on March 12, Coeur would propose to file Amendment No. 3 to the Registration Statement (“Amendment No. 3”) on March 16, 2015. Thereafter,
Coeur would prefer for the Registration Statement to be declared effective as soon as reasonably possible, bearing in mind that the Staff of the Division of Corporation Finance (the “Staff”) will need sufficient time to review filing
before declaring it effective.

 Along those lines, set forth in this response letter are the changes that Coeur proposes to make in
Amendment No. 3. We would greatly appreciate if the Staff could advise us whether or not these changes will be sufficient to resolve all of the Staff’s comments.

For convenience of reference, the Staff’s comments have been reproduced herein in bold. Capitalized terms used but not defined in this
letter have the meanings ascribed thereto in the Registration Statement.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

March 13, 2015

 Page 2

 Material U.S. Federal Income Tax Consequences of the Spin-Off and the Merger, page 72

Comment 1: We note the revisions to this section to reflect that the merger “should” qualify as a reorganization within the meaning of
Section 368(a) of the Code. However, the forms of the opinion filed as Exhibits 8.1 and 8.2 continue to reflect that the merger “will” qualify as a reorganization. Please reconcile. In addition, please revise the disclosure in this
section to provide a more detailed discussion as to why counsel cannot give a “will” opinion and describe the degree of uncertainty in the opinion. For guidance, see Staff Legal Bulleting No. 19 at
http://www.sec.gov/interps/legal/cfslb19.htm. In addition, once the executed opinions have been filed please revise this section to clearly reflect the opinion of counsel.

Coeur respectfully acknowledges the Staff’s comment. As discussed with Ms. Howell, the applicable disclosure in the Registration
Statement will be revised to include the reasons for the “should” opinion. Set forth below is a marked version that shows the changes to be made in the section entitled “The Issuance of Coeur Shares and the Adoption of the Merger
Agreement—Material U.S. Federal Income Tax Consequences of the Spin-Off and the Merger—The Merger.”

 “The Merger

 The obligations of Paramount and Coeur to consummate the merger are conditioned, respectively, on Paramount’s
receipt of a tax opinion from LeClairRyan, A Professional Corporation, and Coeur’s receipt of a tax opinion from Gibson Dunn, in each case, to the effect that, on the basis of the facts, representations, assumptions and exclusions set forth in
such opinion and certificates to be obtained from officers of Paramount and Coeur, the merger should qualify as a “reorganization” within the meaning of Section 368(a) of the Code.

An opinion that the merger “should” qualify as a reorganization within the meaning of Section 368(a) of
the Code expresses a level of comfort that is stronger than “more likely than not” but less than “will.” Counsel is unable to provide a higher degree of certainty because there is no administrative or judicial authority that
directly addresses facts similar to those of this transaction. Nonetheless, counsel believes that its opinion is justified based on the existing authorities.

Consequences to Paramount and Paramount Stockholders

Paramount will not recognize any gain or loss for U.S. federal income tax purposes as a result of the merger.

Paramount stockholders should not recognize any gain or loss pursuant to the merger except in respect of cash received instead
of a fractional share of Coeur common stock (as discussed below). The aggregate tax basis of the Coeur common stock received in the merger (including fractional shares deemed received and redeemed as discussed

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

March 13, 2015

 Page 3

below) should be equal to the aggregate adjusted tax basis of the shares of Paramount common stock surrendered for the Coeur common stock, and the holding period of the Coeur common stock
(including fractional shares deemed received and redeemed) should include the period during which the shares of Paramount common stock were held.

A Paramount stockholder that receives cash instead of a fractional share of Coeur common stock should generally be treated as
having received such fractional share and then as having received such cash in redemption of the fractional share. Gain or loss will generally be recognized based on the difference between the amount of cash received instead of the fractional share
and the portion of the holder’s aggregate adjusted tax basis in the shares of Paramount common stock surrendered which is allocable to the fractional share. Such gain or loss generally will be long-term capital gain or loss if the holding
period for such shares of Paramount common stock is more than one year at the effective time of the merger. Long-term capital gains of non-corporate taxpayers are subject to reduced rates of taxation. The deductibility of capital losses is subject
to limitations.

 The tax opinions from LeClairRyan and Gibson Dunn are not binding on the Internal Revenue Service or the
courts, and neither Paramount nor Coeur intends to request a ruling from the Internal Revenue Service regarding the U.S. federal income tax consequences of the merger. Further, there is no administrative or judicial authority that directly addresses
facts similar to those of this transaction. Consequently, no assurance can be given that the Internal Revenue Service will not assert, or that a court would not sustain, a position contrary to any of those set forth above. In particular, if all or a
portion of the value of SpinCo common stock received by Paramount stockholders is treated as consideration received in the merger, the merger may not qualify as a “reorganization” within the meaning of Section 368(a)
of the Codewould not qualify as a “reorganization” within the meaning of Section 368(a)(1)(B) of the Code, which requires that the consideration for the shares of Paramount common stock consist solely of voting stock of
Coeur. In such case, in order for the merger to qualify as a “reorganization” within the meaning of Section 368(a) of the Code, the merger would have to satisfy the requirements of Section 368(a)(2)(E) of the Code. It is unclear
whether the merger will satisfy such requirements because, among other things, those requirements require a factual determination that may not be able to be made until after the spin-off and merger have been completed. In addition, if any of
the representations or assumptions upon which such opinions are based is inconsistent with the actual facts, the U.S. federal income tax consequences of the merger could be different from those set forth above. If the merger does not qualify as a
reorganization, a Paramount stockholder would recognize gain or loss equal to the difference between the fair market value of the consideration received in the merger and that holder’s adjusted tax basis in its shares of Paramount common stock
surrendered. For this purpose, gain or loss must be calculated separately for each identifiable block of shares (i.e., shares purchased on the same date for the same price) surrendered in the exchange. Paramount stockholders should consult their tax
advisors regarding the particular consequences to them of a taxable transaction.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

March 13, 2015

 Page 4

 Consequences to Coeur and Coeur Stockholders

There will be no U.S. federal income tax consequences to Coeur or Coeur stockholders as a result of the merger.”

The Modified San Miguel Projections, page 78

Comment 2: We note your response to comment two regarding the considerations given to the determination of the time period included in the calculations of
the San Miguel Project. Please provide more detailed support for your reference to the diminished value contribution from cash flows in future periods. Also, please advise why you have not included cash flow projections in the tables, given the use
of the projections in the discounted cash flows analysis.

 Coeur respectfully advises the Staff that, in the discounted cash flow
analysis, future cash flows were discounted to present value using a discount rate reflective of industry norms for silver and gold companies. Through this discounting mechanic, future cash flows are inherently worth less than more near-term cash
flows. This diminution becomes greater the longer the period involved. For example, using a discount rate of 10%, a cash inflow of $50 million in five years has a present value of only $31 million, while a cash inflow of $50 million in ten years has
a present value of only $19 million. In addition to these diminutions, Coeur further advises the Staff that it believes that the most relevant projections for investors to consider are for the next five years because significant uncertainties
(including with respect to commodities prices and mine development plans) exist with respect to projections that are longer in duration. Coeur believes this to be the case, even if future cash flows after five-years contribute positively in the
discounted cash flow analysis.

 In addition, the applicable disclosure in the Registration Statement will be revised to include cash flow
projections. Set forth below is a marked table that shows the added information in the section entitled “The Issuance of Coeur Shares and the Adoption of the Merger Agreement—The Modified San Miguel Projections.”

“Modified San Miguel Projections—Case A

2015

2016

2017

2018

2019

 Silver Production (in millions of ounces)

0.0

0.0

0.5

0.1

3.6

 Gold Production (in thousands of ounces)

0.0

0.0

3.8

3.6

32.8

 Revenues (in millions)

$
0.0

$
0.0

$
14.5

$
7.4

$
114.1

 EBITDA (in millions)

$
0.0

$
0.0

$
8.8

$
(7.2
)

$
57.3

 CAPEX (in millions)

$
0.0

$
0.0

$
(69.6
)

$
(231.7
)

$
(34.4
)

 Free Cash Flow (in millions)

$
0.0

$
0.0

$
(61.6
)

$
(238.4
)

$
18.1

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

March 13, 2015

 Page 5

 Modified San Miguel Projections—Case B

2015

2016

2017

2018

2019

 Silver Production (in millions of ounces)

0.0

0.0

0.5

0.1

3.6

 Gold Production (in thousands of ounces)

0.0

0.0

3.8

3.6

32.8

 Revenues (in millions)

$
0.0

$
0.0

$
14.5

$
7.4

$
114.1

 EBITDA (in millions)

$
0.0

$
0.0

$
8.8

$
(7.2
)

$
57.3

 CAPEX (in millions)

$
0.0

$
0.0

$
(58.4
)

$
(117.0
)

$
(34.4
)

 Free Cash Flow (in millions)

$
0.0

$
0.0

$
(50.3
)

$
(123.7
)

$
18.1

 Modified San Miguel Projections—Case C

2015

2016

2017

2018

2019

 Silver Production (in millions of ounces)

0.0

1.4

2.8

4.6

4.7

 Gold Production (in thousands of ounces)

0.0

25.8

61.5

90.3

76.6

 Revenues (in millions)

$
0.0

$
59.5

$
131.8

$
207.2

$
194.3

 EBITDA (in millions)

$
(3.0
)

$
31.8

$
74.9

$
125.4

$
108.1

 CAPEX (in millions)

$
(15.1
)

$
(23.8
)

$
(14.1
)

$
(19.1
)

$
(12.6
)

 Free Cash Flow (in millions)

$
(18.1
)

$
6.2

$
49.6

$
63.3

$
61.5

 Modified San Miguel Projections—Case D

2015

2016

2017

2018

2019

 Silver Production (in millions of ounces)

0.0

1.4

2.8

4.6

4.7

 Gold Production (in thousands of ounces)

0.0

25.8

61.5

90.3

76.6

 Revenues (in millions)

$
0.0

$
55.6

$
123.7

$
190.8

$
176.0

 EBITDA (in millions)

$
(3.0
)

$
27.9

$
66.8

$
109.2

$
89.9

 CAPEX (in millions)

$
(15.1
)

$
(23.8
)

$
(14.1
)

$
(19.1
)

$
(12.6
)

 Free Cash Flow (in millions)

$
(18.1
)

$
2.6

$
45.4

$
52.2

$
49.7

 Exhibits

Comment 3: We note your response to comment 19 and we reissue the comment. Please file the executed legal and tax opinions prior to requesting effectiveness
and allow us sufficient time to review.

 Coeur respectfully advises the Staff that the executed legal and tax opinions will be filed
as exhibits to Amendment No. 3.

 If you have any questions or comments or require further information with respect to the foregoing,
please do not hesitate to call the undersigned at (212) 351-2389.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

March 13, 2015

 Page 6

Sincerely,

/s/ Eric M. Scarazzo, Esq.

Eric M. Scarazzo, Esq.

cc:
Mitchell J. Krebs

 Coeur Mining, Inc.

Casey M. Nault

 Coeur Mining,
Inc.

March 11 , 2015

Via E -mail
Mr. Mitchell J. Krebs
President and Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, Illinois 60603

Re: Coeur Mining, Inc.
  Amendment No. 2  to Registration Statement on Form S-4
Filed  March 4 , 2015
  File No.  333-201382

Dear Mr. Krebs :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments , we may have additional comments.

Material U.S. Federal Income Tax Consequences of the Spin -Off and the Merger, page 72

1. We note the revisions to this section  to reflect that the merger “should” qualify as a
reorganization within the meaning of Section  368(a) of the Code.  However, the forms of
the opinion filed as Exhibits 8.1 and 8.2 continue to reflect that the merger “will” qualify
as a reorganization.  Please reconcile.  In addition, please revise the disclosure in this
section to provide a more de tailed discussion as to why counsel cannot give a “will”
opinion and describe the degree of uncertainty in the opinion.  For guidance, see Staff
Legal Bulleting No. 19 at http://www.sec.gov/inter ps/legal/cfslb19.htm .  In addition,
once the executed opinions have been filed please revise this section to clearly reflect the
opinion of counsel.

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
March 11 , 2015
Page 2

The Modified San Miguel Projections, page 78

2. We note your response to comment two regarding the considerations given to the
determination of the time period included in the calculations of the San Miguel Project.
Please provide more detailed support for your reference to the diminished value
contrib ution from cash flows in future periods.  Also, please advise why you have not
included cash flow projections in the tables, given the use of the projections in the
discounted cash flows analysis.

Exhibits

3. We note your response to comment four.  Please c onfirm that you will file a pre -effective
amendment with the executed agreements and allow sufficient time for us to review the
executed agreements before effectiveness.

We urge all persons who are responsible for the accuracy and adequacy of the disclosu re
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, the y are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
March 11 , 2015
Page 3

 Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of  the
registration statement.

Please contact Hillary Daniels at (202) 551 -3959  or Pamela Howell  at (202) 551 -3357
with any questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director

cc: Steven R. Shoemate, Esq.
 Gibson, Dunn & Crutcher LLP

CORRESP
1
filename1.htm

CORRESP

 Gibson, Dunn & Crutcher LLP

 200 Park Avenue

New York, NY 10166-0193

 Tel 212.351.4000

 www.gibsondunn.com

 March 3, 2015

VIA EDGAR CORRESPONDENCE

 United States
Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

Attention:
Mr. John Reynolds, Assistant Director

Ms. Pamela Howell

Ms. Hillary Daniels

Re:
Response to SEC Staff Comment Letter dated February 23, 2015

Coeur Mining, Inc.

Amendment No. 1 to Registration Statement on Form S-4

Filed February 9, 2015

File No. 333-201382

 Dear
Mr. Reynolds, Ms. Howell and Ms. Daniels:

 On behalf of Coeur Mining, Inc. (“Coeur”), this letter
responds to your letter, dated February 23, 2015 (the “Comment Letter”), regarding the above referenced filing (as amended from time to time, the “Registration Statement”) relating to the proposed acquisition of Paramount
Gold and Silver Corp. (“Paramount”) by Coeur. Amendment No. 2 to the Registration Statement (“Amendment No. 2”) is being filed today by electronic submission. For your convenience, we have provided under separate cover
four marked copies of Amendment No. 2, which have been marked to show all changes made since Amendment No. 1 to the Registration Statement.

 Set forth below are Coeur’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the
“Commission”) contained in the Comment Letter. For convenience of reference, the Staff’s comments have been reproduced herein in bold. Please note that all page numbers in our responses are references to the page numbers of Amendment
No. 2 as filed on EDGAR, unless otherwise noted. Capitalized terms used but not defined in this letter have the meanings ascribed thereto in the Registration Statement.

 Mr. John Reynolds

 Ms. Pamela Howell

 Ms. Hillary Daniels

March 3, 2015

 Page 2

Opinion of Coeur’s Financial Advisor, page 48

 Comment 1: We note that the discounted cash flow analysis included the consensus pricing of gold and silver in one scenario and Coeur pricing in the other scenario. Please revise to include the
consensus pricing and the Coeur pricing. In addition, please disclose the Estimated Capital Savings used in the Selected Companies Analysis and Selected Transactions Analysis.

The applicable disclosure in the Registration Statement has been revised in response to this Comment. Please see pages 53 and 80 of
Amendment No. 2.

 The Modified San Miguel Projections, page 78

 Comment 2: Please provide clear disclosure in this section as to the modifications and assumptions for the four modifications to the San Miguel Projections. In addition, please advise us as to the
considerations made in determining the time period included in these calculations.

 The applicable disclosure in the
Registration Statement has been revised in response to this Comment. Please see page 80 of Amendment No. 2.

 In addition,
Coeur respectfully advises the Staff that it believes that the most relevant projections for investors to consider are for the next five years. Among other uncertainties, commodities prices and mine development plans are subject to significant
variation over time, and using a longer period would lower Coeur’s confidence in the veracity of the projections. In addition, a discounted cash flow analysis inherently diminishes the value contribution from cash flows in future periods, and
this diminution becomes greater the longer the time period involved.

 The Voting and Support Agreement, page 83

Comment 3: We note your response to comment 17 and we reissue the comment. Please include the amount and percent of shares of Paramount that
shareholders have agreed to vote in favor of the merger agreement in your next amendment.

 The applicable disclosure in
the Registration Statement has been revised in response to this Comment. Please see pages 10 and 89 of Amendment No. 2.

 Exhibits

 Comment 4: We note your response to comment 19 and we reissue the comment. Please file the executed legal and tax opinions prior to
requesting effectiveness and allow us sufficient time to review.

 Coeur respectfully advises the Staff that the legal and
tax opinions will be executed on and dated the date that the Registration Statement is declared effective, as required by the closing conditions in the merger agreement. At that time, fully executed legal and tax opinions will be filed as exhibits
to the Registration Statement. Coeur confirms to the Staff that the fully executed opinions will be identical in all respects to the forms of opinion filed with Amendment No. 2.

* * *

 Mr. John Reynolds

 Ms. Pamela Howell

 Ms. Hillary Daniels

March 3, 2015

 Page 3

In addition, in connection with Comment 1 in your previous letter, dated January 29, 2015, Coeur notes for the Staff that the
financial statements of Coeur for the year ended December 31, 2014 have been incorporated by reference in Amendment No. 2 and, therefore, Coeur has recalculated the significance tests using such 2014 figures to determine whether Coeur is
required to file pro forma financial information required by Article 11 of Regulation S-X (“Article 11”). The calculations below continue to use the audited financial information of Paramount for its year ended June 30, 2014.

 Coeur respectfully notes that no pro forma financial information is required by Article 11 because the significance of the
Paramount acquisition, as calculated pursuant to Regulation S-X, Rule 1-02(w) (“Rule 1-02(w)”), is less than 20%.

Item 5 of Form S-4 requires disclosure of financial information, if any, required by Article 11. Rule 11-01(a) of Regulation S-X
requires pro forma financial information in circumstances where a “significant” business combination has occurred or is probable. An acquisition is considered significant for these purposes if the business to be acquired would be
significant pursuant to the conditions of Rule 1-02(w) at the 20% level. Accordingly, pro forma financial information with respect to the Paramount acquisition would be required in the Registration Statement only if one of the following conditions
were met:

 (1) Coeur’s investments in and advances to Paramount exceed 20% of the total consolidated assets of Coeur as
of the end of Coeur’s most recently completed fiscal year (the “investment test”);

 (2) Coeur’s
proportionate share of Paramount’s total assets (after intercompany eliminations) exceeds 20% of Coeur’s total consolidated assets as of the end of Coeur’s most recently completed fiscal year (the “assets test”); or

 (3) Coeur’s equity in income from continuing operations before income taxes, extraordinary items and cumulative effect
of a change in accounting principle exclusive of amounts attributable to any noncontrolling interests (“Test Income”) of Paramount exceeds 20% of such income of Coeur on a consolidated basis for Coeur’s most recently completed fiscal
year (the “income test”).

 Based on this definition, the Paramount business to be acquired does not meet any of the
three tests.

 Coeur’s most recently completed fiscal year for which financial statements are included in the Registration
Statement is the year ended December 31, 2014. Coeur’s consolidated total assets as of December 31, 2014 were $1,455.4 million. Paramount’s most recently completed fiscal year ended June 30, 2014. Paramount’s
consolidated total assets at June 30, 2014 were $62.3 million. As such, Paramount’s significance under the assets test is 4.3%.

 Mr. John Reynolds

 Ms. Pamela Howell

 Ms. Hillary Daniels

March 3, 2015

 Page 4

The proposed acquisition of Paramount by Coeur is to be accounted for by the purchase method of accounting. The purchase price of
Paramount (the “investment in and advances to” Paramount) is approximately $154.7 million (calculated as 32.7 million shares at the announcement date 20 day VWAP of $4.47 plus $8.5 million equity financing of SpinCo). As such,
Paramount’s significance under the investment test is 10.6%. The final purchase price will be based on Coeur’s stock price at the closing date; however, to be considered significant, Coeur’s stock price would need to reach $8.64.

 Coeur’s Test Income for the year ended December 31, 2014 was $(1,615.1) million, and Paramount’s Test Income
for the year ended June 30, 2014 was $(11.1) million. As such, Paramount’s significance under the income test is 0.7%.

* * *

 If you
have any questions or comments or require further information with respect to the foregoing, please do not hesitate to call the undersigned at (212) 351-3879.

Sincerely,

 /s/ Steven R. Shoemate, Esq.

 Steven R. Shoemate, Esq.

cc:
Mitchell J. Krebs

Coeur Mining, Inc.

Casey M. Nault

Coeur Mining, Inc.

February 23, 2015

Via E -mail
Mr. Mitchell J. Krebs
President and Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, Illinois 60603

Re: Coeur Mining, Inc.
  Amendment No. 1 to Registration Statement on Form S-4
Filed  February 9 , 2015
  File No.  333-201382

Dear Mr. Krebs :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments , we may have additional comments.

Opinion of Coeur’s Financial Advisor, page 48

1. We note that the discounted cash flow analysis included the consensus pricing of gold
and silver in one scenario and Coeur pricing in the other scenario.  Please revise to
include the consensus pricing and the Coeur pricing.  In addition, please disclose the
Estimated Capital Savings used in the Selected Companies Analysis and Selected
Transactions Analysis.

The Modified San Miguel Projections, page 78

2. Please provide clear disclosure in this section as to the modifications and assumptions for
the four modifications to the San Miguel Projections.   In addition, please advise us as to
the considerations made in determining the time period included in these calculations.

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
February 23 , 2015
Page 2

The Voting and Support Agreement, page 83

3. We note your response to comment 17 and we reissue the comment.  Please include the
amount and percent of shares of Paramount that shareholders have agreed to vote in favor
of the merger agreement in your next a mendment.

Exhibits

4. We note your response to comment 19 and we reissue the comment.  Please file the
executed legal and tax opinions prior to requesting effectiveness and allow us sufficient
time to review.

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 the Securities Act of 193 3 and
all applicable Securities  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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commissi on from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and acc uracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to rev iew any amendment prior to the requested effective date of the
registration statement.

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
February 23 , 2015
Page 3

 Please contact Hillary Daniels at (202) 551 -3959  or Pamela Howell  at (202) 551 -3357
with any questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director

cc: Steven R. Shoemate, Esq.
 Gibson, Dunn & Crutcher LLP

CORRESP
1
filename1.htm

CORRESP

 Gibson, Dunn & Crutcher LLP

200 Park Avenue

 New York,
NY 10166-0193

 Tel 212.351.4000

www.gibsondunn.com

 February 9, 2015

 VIA EDGAR CORRESPONDENCE

 United States Securities
and Exchange Commission

 Division of Corporation Finance

 100
F Street, N.E.

 Washington, D.C. 20549

Attention:
Mr. John Reynolds, Assistant Director

Ms. Pamela Howell

Ms. Hillary Daniels

Re:
Response to SEC Staff Comment Letter dated January 29, 2015

 Coeur Mining,
Inc.

 Registration Statement on Form S-4 filed January 7, 2015

File No. 333-201382

 Dear
Mr. Reynolds, Ms. Howell and Ms. Daniels:

 On behalf of Coeur Mining, Inc. (“Coeur”), this letter responds to
your letter, dated January 29, 2015 (the “Comment Letter”), regarding the above referenced filing (as amended from time to time, the “Registration Statement”) relating to the proposed acquisition of Paramount Gold and Silver
Corp. (“Paramount”) by Coeur. Amendment No. 1 to the Registration Statement (“Amendment No. 1”) is being filed today by electronic submission. For your convenience, we have provided under separate cover four marked
copies of Amendment No. 1, which have been marked to show all changes made to the original Registration Statement.

 Set forth below
are Coeur’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) contained in the Comment Letter. For convenience of
reference, the Staff’s comments have been reproduced herein in bold. Please note that all page numbers in our responses are references to the page numbers of Amendment No. 1 as filed on EDGAR, unless otherwise noted. Capitalized terms used
but not defined in this letter have the meanings ascribed thereto in the Registration Statement.

 General

Comment 1: Please include the pro forma financial information required by Article 11 of Regulation S-X. Refer to Item 5 of Form S-4.

The Company respectfully notes that no pro forma financial information is required by Article 11 of Regulation S-X (“Article 11”)
because the significance of the Paramount acquisition, as calculated pursuant to Regulation S-X, Rule 1-02(w) (“Rule 1-02(w)”), is less than 20%.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

February 9, 2015

  Page
 2

 Item 5 of Form S-4 requires disclosure of financial information, if any, required by
Article 11. Rule 11-01(a) of Regulation S-X requires pro forma financial information in circumstances where a “significant” business combination has occurred or is probable. An acquisition is considered significant for these purposes if
the business to be acquired would be significant pursuant to the conditions of Rule 1-02(w) at the 20% level. Accordingly, pro forma financial information with respect to the Paramount acquisition would be required in the Registration Statement only
if one of the following conditions were met:

(1)
Coeur’s investments in and advances to Paramount exceed 20% of the total consolidated assets of Coeur as of the end of Coeur’s most recently completed fiscal year (the “investment test”);

(2)
Coeur’s proportionate share of Paramount’s total assets (after intercompany eliminations) exceeds 20% of Coeur’s total consolidated assets as of the end of Coeur’s most recently completed fiscal year
(the “assets test”); or

(3)
Coeur’s equity in income from continuing operations before income taxes, extraordinary items and cumulative effect of a change in accounting principle exclusive of amounts attributable to any noncontrolling
interests (“Test Income”) of Paramount exceeds 20% of such income of Coeur on a consolidated basis for Coeur’s most recently completed fiscal year (the “income test”).

Based on this definition, the Paramount business to be acquired does not meet any of the three tests.

Coeur’s most recently completed fiscal year for which financial statements are included in the Registration Statement is the year ended
December 31, 2013. Coeur’s consolidated total assets as of December 31, 2013 were $2,886.0 million. Paramount’s most recently completed fiscal year ended June 30, 2014. Paramount’s consolidated total assets at
June 30, 2014 were $62.3 million. As such, Paramount’s significance under the asset test is 2.2%.

 The proposed acquisition of
Paramount by Coeur is to be accounted for by the purchase method of accounting. The purchase price of Paramount (the “investment in and advances to” Paramount) is approximately $154.7 million (calculated as 32.7 million shares at the
announcement date 20 day VWAP of $4.47 plus $8.5 million equity financing of SpinCo). As such, Paramount’s significance under the investment test is 5.4%. The final purchase price will be based on Coeur’s stock price at closing date;
however, to be considered significant, Coeur’s stock price would need to reach $17.40.

 Coeur’s Test Income for the year ended
December 31, 2013 was $(808.7) million, and Paramount’s Test Income for the year ended June 30, 2014 was $(11.1) million. As such, Paramount’s significance under the income test is 1.4%.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

February 9, 2015

  Page
 3

 Coeur notes for the Staff that, if the financial statements of Coeur for the year ended
December 31, 2014 are to be included in the Registration Statement when it is declared effective, Coeur will recalculate the significance tests using such numbers. If significance were to exceed 20% on such basis, Coeur also would file in the
Registration Statement all pro forma financial information required by Article 11. That said, Coeur currently expects Paramount’s significance to be substantially below 20% when recalculated for the year ended December 31, 2014.

Summary Historical Financial Data of Coeur, page 12

Comment 2: Please revise your financial data section to include the pro forma information required by Item 3 of Form S-4.

The applicable disclosure in the Registration Statement has been revised to include the pro forma selected financial data and per share data
required by Item 3(e) and 3(f) of Form S-4 in response to this Comment. Please see pages 15, 16 and 17 of Amendment No. 1.

 Comparative
Per Share Information, page 15

 Comment 3: Please revise to present in comparative columnar form (a) historical and pro forma per share
data for Coeur and (b) historical and equivalent pro forma per share data for Paramount. Refer to Item 3(f) of Form S-4.

 As
set forth above in Coeur’s response to Comment 2, the applicable disclosure in the Registration Statement has been revised to include the historical and pro forma per share data required by Item 3(f) of Form S-4 in response to this
Comment. Please see pages 16 and 17 of Amendment No. 1.

 Background of the Merger, page 37

Comment 4: Please identify the investment bank that had a representative at the September 5, 2014 meeting.

The applicable paragraph in the Registration Statement has been revised in response to this Comment. Please see page 41 of Amendment
No. 1.

 Comment 5: Discuss in greater detail the non-dilutive financing opportunities sought by Paramount. Also, please discuss whether any other
strategic alternatives were considered.

 The applicable paragraph in the Registration Statement has been revised in response to this
Comment. Please see pages 41 and 48 of Amendment No. 1.

 Comment 6: We note disclosure that a special committee was formed by the Paramount board
to consider a proposed transaction between SpinCo and a third party. Please add disclosure regarding how the members of the committee were selected and what duties they were given.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

February 9, 2015

  Page
 4

 The applicable paragraph in the Registration Statement has been revised in response to this
Comment. Please see page 42 of Amendment No. 1.

 Comment 7: We note the financial advisors for Coeur Mining and Paramount provided oral opinions
to the respective boards on December 15, 2014, which were subsequently confirmed in writing. Please provide us supplemental copies of any materials, such as board books, used in their presentations to the board. We may have additional comments
after reviewing these materials.

 A copy of the presentation materials provided to Coeur’s board of directors on
December 15, 2014 by Raymond James Ltd. (“Raymond James”) for purposes of their fairness opinion analysis will be furnished supplementally to the Staff by McGuireWoods LLP, counsel to Raymond James, under separate cover requesting
confidential treatment of such materials under the Freedom of Information Act. Raymond James will request that such materials be returned promptly to McGuireWoods LLP following completion of the Staff’s review thereof.

A copy of the presentation materials provided to Paramount’s board of directors on December 15, 2014 by Scotia Capital (USA) Inc.
(“Scotia Capital”) for purposes of their fairness opinion analysis will be furnished supplementally to the Staff by Paul, Weiss, Rifkind, Wharton & Garrison LLP, counsel to Scotia Capital, under separate cover requesting
confidential treatment of such materials under the Freedom of Information Act. Scotia Capital will request that such materials be returned promptly to Paul, Weiss, Rifkind, Wharton & Garrison LLP following completion of the Staff’s
review thereof.

 Paramount’s Reasons for the Merger; Recommendation of the Paramount Board of Directors, page 45

Comment 8: We note your disclosure on page 37 that the Paramount board has considered other transactions in the past. Please add disclosure regarding any
consideration given by the Paramount board regarding alternatives to the transaction, including with other companies in the industry.

The applicable disclosure in the Registration Statement has been revised in response to this Comment. Please see page 48 of Amendment
No. 1.

 Opinion of Coeur’s Financial Advisor, page 48

Comment 9: We note the disclosure on page 49 that the Paramount Projections were provided to Raymond James through Coeur. Please revise your registration
statement to disclose the Paramount Projections.

 The applicable disclosure in the Registration Statement has been revised in response
to this Comment. Please see pages 24, 25, 26, 78, 79 and 80 of Amendment No. 1.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

February 9, 2015

  Page
 5

 Comment 10: We note disclosure on page 51 that Raymond James considered the estimated Capital Savings in
its analysis. We also note the Coeur-Paramount Projections used in the Discounted Cash Flow Analysis on page 53. Please disclose these projections.

The applicable disclosure in the Registration Statement has been revised in response to this Comment. Please see pages 24, 25, 26, 55, 56, 78,
79 and 80 of Amendment No. 1.

 Comment 11: We note the companies considered in the Selected Companies Analysis and the Selected Transaction
Analysis. Please advise whether any additional companies fit within the criteria but were not analyzed, and if so, why they were excluded.

The applicable disclosure in the Registration Statement has been revised in response to this Comment. Please see pages 53, 54 and 55 of
Amendment No. 1. Coeur respectfully advises the Staff that it has been advised by Raymond James that no company that fit within the criteria established by Raymond James in conducting the Selected Companies Analysis and the Selected Transaction
Analysis was excluded.

 Comment 12: Please describe the method of selection of Raymond James by Coeur Mining, Inc. Refer to Item 1015(b)(3) of
Regulation M-A for guidance.

 The applicable paragraph in the Registration Statement has been revised in response to this Comment.
Please see page 50 of Amendment No. 1.

 Comment 13: Please expand the compensation disclosure on page 55 to disclose the aggregate compensation
received by Raymond James in the past two years for all services. Refer to Section 1015(b)(4) of Regulation M-A for guidance.

The applicable paragraph in the Registration Statement has been revised in response to this Comment. Please see page 57 of Amendment
No. 1.

 Comment 14: Please revise the compensation disclosure on page 55 to clearly state the amount of the compensation that is contingent upon
the closing of the transaction.

 The applicable paragraph in the Registration Statement has been revised in response to this Comment.
Please see page 57 of Amendment No. 1.

 Opinion of Paramount’s Financial Advisor, page 55

Comment 15: Please clarify with greater specificity the criteria used to determine the comparable precedent transactions on page 61. Please advise whether
any additional transactions fit within the criteria but were not analyzed, and if so, why they were excluded. Provide similar disclosure for the companies on page 64.

The applicable disclosure in the Registration Statement has been revised in response to this Comment. Please see page 63 and 66 of Amendment
No. 1. Coeur respectfully advises the Staff that it has been advised by Scotia Capital that no transaction that fit within the comparable precedent transactions criteria was intentionally excluded from Scotia Capital’s analysis.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

February 9, 2015

  Page
 6

 Comment 16: Please clarify on page 61 how the P/NAV range and EV/Resource range used in determining the
generated illustrated values were determined. Please revise similar disclosure on page 64.

 The applicable disclosure in the
Registration Statement has been revised in response to this Comment. Please see pages 63 and 66 of Amendment No. 1.

 The Voting and Support
Agreement, page 83

 Comment 17: Please disclose the amount and percent of shares of Paramount that shareholders have agreed to vote in favor of
the merger agreement.

 The applicable disclosure in the Registration Statement has been revised in response to this Comment. Please
see pages 10 and 88 of Amendment No. 1.

 Exhibits

Comment 18: Please remove from the legality opinion the statement that you are not admitted to practice in the state of Delaware, as it is a limitation on
the opinion. For guidance, see SLB 19.

 Counsel has revised the legality opinion to in response to this Comment. Please see Exhibit
5.1 to Amendment No. 1.

 Comment 19: We note that you have filed the forms of the legal and tax opinions. Please file the executed opinions prior
to requesting effectiveness.

 Coeur respectfully advises the Staff that the legal and tax opinions will be executed on and dated the
date that the Registration Statement is declared effective. At that time, fully executed legal and tax opinions will be filed as exhibits to the Registration Statement.

Comment 20: Please file the royalty agreement as an exhibit or incorporate it by reference in the exhibits index.

The exhibit index in the Registration Statement has been revised in response to this Comment. We respectfully note to the Staff that the
royalty agreement was already incorporated by reference into the Registration Statement as it is an exhibit to a Form 8-K filed by Paramount, which itself is incorporated by reference.

If you have any questions or comments or require further information with respect to the foregoing, please do not hesitate to call the
undersigned at (212) 351-3879.

 Mr. John Reynolds

Ms. Pamela Howell

 Ms. Hillary Daniels

February 9, 2015

  Page
 7

 Sincerely,

/s/ Steven R. Shoemate, Esq.

Steven R. Shoemate, Esq.

cc:
Mitchell J. Krebs

 Coeur Mining, Inc.

Casey M. Nault

 Coeur Mining,
Inc.

January 29 , 2015

Mr. Mitchell J. Krebs
President and Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, Illinois 60603

Re: Coeur Mining, Inc.
  Registration Statement on Form S-4
Filed  January 7, 2015
  File No.  333-201382

Dear Mr. Krebs :

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information.   Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these comments , we may have additional comments.

General

1. Please include the pro forma financial information required by Article 11 of Regulation
S-X.  Refer to Item 5 of Form S -4.

Summary Historical Financial Data of Coeur, page 12

2. Please revise your financial dat a section to include the pro forma information required by
Item 3 of Form S -4.

Comparative Per Share Information, page 15

3. Please revise to present in comparative columnar form (a) historical and pro forma per
share data for Coeur and (b) historical and e quivalent pro forma per share data for
Paramount.  Refer to Item 3(f) of Form S -4.

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
January 29 , 2015
Page 2

 Background of the Merger, page 37

4. Please identify the investment bank that had a representative at the September 5, 2014
meeting.

5. Discuss in greater detail the non-dilutive financing opportunities sought by Paramount.
Also, please discuss whether any other strategic alternatives were considered.

6. We note disclosure that a special committee was formed by the Paramount board to
consider a proposed transaction betw een SpinCo and a third party.  Please add disclosure
regarding how the members of the committee were selected and what duties they were
given .

7. We note the financial advisors for Coeur Mining and Paramount provided oral opinions
to the respective boards on  December 15, 2014, which were subsequently confirmed in
writing.  Please provide us supplemental copies of any materials, such as board books,
used in their presentations to the board.   We may have additional comments after
reviewing these materials.

Paramount’s Reasons for the Merger; Recommendation of the Paramount Board of Directors,
page 45

8. We note your disclosure on page 37 that the Paramount board has considered other
transactions in the past.  Please add disclosure regarding any consideration give n by the
Paramount board regarding alternatives to the transaction, including with other
companies in the industry.

Opinion of Coeur’s Financial Advisor, page 48

9. We note the disclosure on page 49 that the Paramount Projections were provided to
Raymond J ames through Coeur.  Please revise your registration statement to disclose the
Paramount Projections.

10. We note disclosure on page 51 that Raymond James considered the estimated Capital
Savings in its analysis.  We also note the Coeur -Paramount Projection s used in the
Discounted Cash Flow Analysis on page 53.  Please disclose these projections.

11. We note the companies considered in the Selected Companies Analysis and the Selected
Transaction Analysis.  Please advise whether any additional companies fit with in the
criteria but were not analyzed, and if so, why they were excluded.

12. Please describe the method of selection of Raymond James by Coeur Mining, Inc.  Refer
to Item 1015(b)(3) of Regulation M -A for guidance.

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
January 29 , 2015
Page 3

 13. Please expand the compensation disclosure on page 55 to disclose the aggregate
compensation  received by Raymond James in the past two years for all services.  Refer to
Section 1015(b)(4) of Regulation M -A for guidance.

14. Please revise the compensation disclosure on page 55 to clearly state the amou nt of the
compensation that is contingent upon the closing of the transaction.

Opinion of Paramount’s Financial Advisor, page 55

15. Please clarify with greater specificity the criteria used to determine the comparable
precedent transactions on page 61.  Ple ase advise whether any additional transactions fit
within the criteria but were not analyzed, and if so, why they were excluded.  Provide
similar disclosure for the companies on page 64.

16. Please clarify on page 61 how the P/NAV range and EV/Resource range used in
determining the generated illustrated values were determined.  Please revise similar
disclosure on page 64.

The Voting and Support Agreement, page 83

17. Please disclose the amount and percent of shares of Paramount that shareholders have
agreed to v ote in favor of the merger agreement.

Exhibits

18. Please remove from the legality opinion the statement that you are not admitted to
practice in the state of Delaware, as it is a limitation on the opinion.  For guidance, see
SLB 19.

19. We note that you have f iled the forms of the legal and tax opinions.  Please file the
executed opinions prior to requesting effectiveness.

20. Please file the royalty agreement as an exhibit or incorporate it by reference in the
exhibits index.

We urge all persons who are responsi ble for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  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.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

Mr. Mitchell J. Krebs
Coeur Mining, Inc.
January 29 , 2015
Page 4

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with re spect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the fi ling; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities unde r
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the req uested effective date of the
registration statement.

Please contact Hillary Daniels at (202) 551 -3959  or Pamela Howell  at (202) 551 -3357
with any questions.

Sincerely,

 /s/ Pamela Howell
 for

John Reynolds
Assistant Director

cc: Steven R. Shoemate, Esq.
 Gibson, Dunn & Crutcher LLP

January 5, 2015

Via E -mail
Mr. Mitchell J.  Krebs
President and Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Avenue, Suite 900
Chicago, IL 60603

 Re: Coeur Mining, Inc.
  Form 10 -K for the Year Ended December 31, 2013
  Filed February 26, 2014
  File No. 001 -08641

Dear Mr. Krebs :

We have completed our review of your filing s.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 la ws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require .

        Sincerely,

        /s/ Rufus Decker for

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

CORRESP
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		4Q14 CDE SEC Comment Response

December 22, 2014

VIA EDGAR AND HAND DELIVERY

Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:

 Coeur Mining, Inc.

Form 10-K for the Year Ended December 31, 2013

Filed February 26, 2014

File No. 001-08641

Dear Ms. Jenkins:

On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated December 11, 2014 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10‑K for the year ended December 31, 2013 (the “Annual Report”), filed with the Securities and Exchange Commission (the “Commission”) on February 26, 2014.  Each comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the corresponding response.  For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.  Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

Form 10-K for the Year Ended December 31, 2013

General

1.

 We note your response to comments 4 and 5 stating your newly-designated royalty segment asset values and revenues are limited in nature, and you believe your property descriptions and consolidated royalty revenue disclosures are appropriate when compared to your total mining operations. In addition, you state that the absence of production results, which form the basis for your royalty revenues, is appropriate when compared to your total revenues. In future filings, if true, please clearly state your royalty segment assets and revenues are not material to your company.

The Company confirms that it will state in future filings, if true, that royalty assets and related revenues included in its Coeur Capital segment are not material to the Company.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

Form 10-Q for the Quarter Ended June 30, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations Highlights - Three months Ended June 30, 2014, page 31

2.

 We note from your response to our prior comment 7 that you did not consider the results of the La Preciosa feasibility study to be a triggering event for the purpose of assessing impairment at June 30, 2014. We also note from disclosures in your Form 8-K filed on July 30, 2014 that:

•

 the 2014 Feasibility Study reported a decrease in the after-tax NPV, estimated initial mine life, silver/gold recovery rate and total silver/gold production compared to your July 2013 Preliminary Economic Assessment;

•

 the after-tax NPV calculated in your Feasibility Study appears to be below the carrying value of your La Preciosa assets; and

•

 since your acquisition of La Preciosa, precious metals prices have decreased and Mexico has increased the taxes on precious metals mines.

Please tell us how you considered these findings and developments in your evaluation of the triggering events for purpose of assessing impairment at June 30, 2014. Provide us your analysis explaining the factors considered including any mitigating factors and the basis for your conclusion. Refer to FASB ASC 360-10-35-21, 35-21(b) and 35-21(c) for further guidance.

The Company acquired the La Preciosa exploration property in April 2013, which had no proven and probable reserves, to add what it considered “a large-scale development opportunity with significant exploration upside.”  At the date of acquisition, and each subsequent reporting period prior to the 2014 Feasibility Study, the Company’s estimated project fair value was based solely on non-reserve mineralized material and related value beyond proven and probable reserves.  The Company conducted the 2014 Feasibility Study to reclassify, to the extent appropriate, non-reserve mineralized material to proven and probable reserves and determine whether an immediate positive development decision was feasible at spot metal prices.

The 2014 Feasibility Study confirmed that the La Preciosa project is a commercially mineable deposit (development opportunity) resulting in an initial declaration of approximately 126 million silver ounces and 209,000 gold ounces in proven and probable reserves.  However, in light of its disciplined capital deployment philosophy and commitment to retaining a flexible, liquid balance sheet, the Company did not immediately begin construction activities upon completion of the study.  As noted in our disclosures on Form 8-K dated July 30, 2014, the Company intends to complete additional exploration and reserve conversion activity by the first half of 2015.

The decrease in the after-tax NPV, estimated initial mine life, silver/gold recovery rates and total silver/gold production in the 2014 Feasibility Study compared to the July 2013 Preliminary Economic Assessment noted above is primarily due to the exclusion of non-reserve mineralized material from the 2014 Feasibility Study valuation, lower silver and gold price assumptions and higher taxes by Mexican tax authorities.   Although the 2014 Feasibility Study valuation did not account for non-reserve mineralized material, the Company’s successful exploration and project evaluation efforts

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

continue to identify non-reserve mineralized material.  Such mineralized material indicates value beyond proven and probable reserves.

In determining whether there was a triggering event at June 30, 2014, the Company considered the results of the 2014 Feasibility Study valuation (including all negative factors noted above) and the project’s estimated value beyond proven and probable reserves and determined that the project’s expected returns at June 30, 2014 were greater than the indicated returns from the 2013 Preliminary Economic Assessment.  We therefore concluded that no triggering event had occurred at June 30, 2014, and in accordance with FASB ASC 360, no further impairment testing was required.

Given the nature of the 2014 Feasibility Study, and readily available life of mine cash flows, the Company determined the project’s estimated undiscounted cash flows exceeded the Company’s carrying value of the La Preciosa project at June 30, 2014.   Therefore, had the Company considered the 2014 Feasibility Study or any related factors to be a triggering event, the carrying value of the long-lived La Preciosa assets were recoverable and no impairment would have been required at June 30, 2014.

*    *    *

The Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) 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 (iii) 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.

We would be pleased to address any further Staff comments or questions related to the above matters.  If the Staff wishes to discuss this letter at any time, please do not hesitate to contact Casey Nault, Vice President, General Counsel and Secretary at (312) 489-5846 or Mark Spurbeck, Vice President, Finance at (312) 489-5863.

Very truly yours,

/s/ PETER C. MITCHELL

Peter C. Mitchell

Senior Vice President and Chief Financial Officer

cc:

 Mitchell J. Krebs, President and Chief Executive Officer

Casey M. Nault, Vice President, General Counsel and Secretary

Mark Spurbeck, Vice President, Finance

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

CORRESP
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		4Q14 CDE SEC Comment Letter

November 19, 2014

VIA EDGAR AND HAND DELIVERY

Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:

 Coeur Mining, Inc.

Form 10-K for the Year Ended December 31, 2013

Filed February 26, 2014

File No. 001-08641

Dear Ms. Jenkins:

On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated November 6, 2014 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10‑K for the year ended December 31, 2013 (the “Annual Report”), filed with the Securities and Exchange Commission (the “Commission”) on February 26, 2014.  Each comment of the Staff of the Division of Corporation Finance of the Commission (the “Staff”) is set forth below, followed by the corresponding response.  For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.  Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

Form 10-K for the Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 31

Critical Accounting Policies and Developments - Impairments, page 33

1.

 We note your disclosure under Note 4 that you recorded an impairment charge of $773 million to mining properties in 2013.  Considering your impairment charges and significant decline in your realized silver and gold prices during the periods reported, to enhance investor’s understanding  regarding your recent impairment testing of long lived assets, please confirm that you will disclose the following in future filings:

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

•

 the amount of long-lived assets (mineral interests and property, plant and equipment) allocated to each of the asset groups that are at risk of impairment and the percentage by which fair value exceeded carrying value as of the date of the most recent test;

•

 a description of the methods and key assumptions used and how the key assumptions were determined;

•

 a discussion of the degree of uncertainty associated with the key assumptions in as specific a manner as practicable;

•

 the factors that affect variability in the pricing assumptions; and,

•

 a description of potential events and/or changes in circumstances that could reasonably be expected to negatively affect the key assumptions.

Please provide us with a draft of your proposed disclosures.  Refer to FR-72, which can be found on our website at: http://www.sec.gov/rules/interp/33-8350.htm.

At December 31, 2013, the Company identified impairment triggering events at its Palmarejo and Kensington mines.  The triggering events identified were sustained and continued operating losses combined with results of the revised life-of-mine plans for those two mines.  The Company did not identify any additional triggering events nor has the Company recorded any goodwill associated with its mining properties or other assets, and therefore, in accordance with FASB ASC 360, the Company did not conduct further impairment testing.  The Company confirms it will enhance its Critical Accounting Policies and Developments - Impairments discussion in future filings to include more specific detail related to key assumptions used in impairment testing and related risk and uncertainties associated with those key assumptions.  An example of the disclosure that would have been included in the Annual Report is as follows:

Impairments

We review and evaluate our long-lived assets for impairment when events or changes in circumstances indicate that the related carrying amounts may not be recoverable.  Asset impairment is considered to exist if the total estimated undiscounted pre-tax future cash flows are less than the carrying amount of the asset.  In estimating future cash flows, assets are grouped at the lowest level for which there is identifiable cash flows that are largely independent of future cash flows from other asset groups.  An impairment loss is measured and recorded based on discounted estimated future cash flows.  Future cash flows are estimated based on estimated quantities of recoverable minerals, expected silver and gold prices (considering current and historical prices, trends and related factors), production levels, operating costs, capital requirements and reclamation costs, all based on life-of-mine plans.  The significant assumptions used in determining future cash flows for each mine site asset group at December 31, 2013, apart from production cost and capitalized expenditure assumptions unique to each operation, included long-term silver and gold prices of $25 and $1,450 per ounce (consistent with the Company’s long-term  reserve prices), respectively, a U.S. to Mexican Peso long-term exchange rate of 12.5, a U.S. to Bolivian Boliviano long-term exchange rate of 6.85 and discount rates ranging from 8.25% - 12.25% (to reflect project and country-specific risks).  During 2013, 2012 and 2011, we recorded impairments of $773.0 million ($642.1 million impairment of the Palmarejo mine and a $130.7 million impairment of the Kensington mine), $5.8 million (Martha mine), and nil, respectively, to reduce the carrying value of mining properties and property, plant and equipment as part of Write-downs.

Existing proven and probable reserves and value beyond proven and probable reserves, including mineralization other than proven and probable reserves are included when determining the fair value of mine site asset groups at acquisition and, subsequently, in determining whether the assets are impaired.  The term “recoverable minerals” refers to the estimated amount of silver and gold that will be obtained after taking into account losses during ore processing and treatment.  Estimates of recoverable minerals from exploration stage mineral interests are risk adjusted based on management’s relative confidence in such materials.  The ability to achieve the estimated quantities of recoverable minerals from exploration stage mineral interests involves further risks in addition to those risk factors applicable to mineral interests where proven and probable

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

reserves have been identified, due to the lower level of confidence that the identified mineralized material could ultimately be mined economically.  Assets classified as exploration potential have the highest level of risk that the carrying value of the asset can be ultimately realized, due to the still lower level of geological confidence and economic modeling.

Silver and gold prices are volatile and affected by many factors beyond the Company’s control, including prevailing interest rates and returns on other asset classes, expectations regarding inflation, speculation, currency values, governmental decisions regarding precious metals stockpiles, global and regional demand and production, political and economic conditions and other factors may affect the key assumptions used in the Company’s impairment testing. Various factors could impact our ability to achieve forecasted production levels from proven and probable reserves.  Additionally, production, capital and reclamation costs could differ from the assumptions used in the cash flow models used to assess impairment.  Actual results may vary from the Company’s estimates and result in additional Write-downs.

Liquidity and Capital Resources, page 40

Cash provided by operating activities, page 40

2.

 We note significant changes in your cash flows from operating activities during the periods presented, for example, cash provided by operating activities decreased by $145 million and $158 million during 2012 and 2013, respectively.  We note that you have provided a general discussion for the reasons for the change.  However, your discussions did not clearly identify the specific quantitative effect of the underlying causal factors responsible for the change.  To enhance an investor’s understanding, please confirm that in future filings you will include robust discussions describing and quantifying the specific effect of the significant drivers that contributed to the material changes in your operating cash flows.  Please provide us with a draft of proposed disclosures to be included in future filings.  Refer to Item 303 of Regulations S-K and SEC Release No. 33-8350 as it relates to liquidity and capital resources for further guidance.

The Company confirms it will provide a more robust discussion in future filings to quantify the specific effects of significant drivers to material changes in operating cash flows.  An example of the disclosure that would have been included in the Annual Report is as follows:

Cash Provided by Operating Activities

Net cash provided by operating activities was $113.5 million, $271.6 million and $416.2 million for the years ended December 31, 2013, 2012 and 2011, respectively and were impacted by the following key factors:

 Year Ended December 31,

 2013

 2012

 2011

Silver equivalent ounces sold (excluding Kensington)

 26,008,123

 26,453,889

 26,975,524

Average realized price per silver equivalent ounce

 $

 22.96

 $

 29.66

 $

 32.25

Costs applicable to sales per silver equivalent ounce (1)

 (13.81

 )

 (13.89

 )

 (11.78

 )

Operating margin per silver equivalent ounce

 $

 9.15

 $

 15.77

 $

 20.47

Gold ounces sold (Kensington)

 117,500

 71,709

 106,583

Average realized price per gold ounce

 $

 1,266

 $

 1,548

 $

 1,418

Costs applicable to sales per gold ounce (1)

 (890

 )

 (1,214

 )

 (950

 )

Operating margin per gold ounce

 $

 376

 $

 334

 $

 468

(1) See Non-GAAP Performance Measures

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

 Year Ended December 31,

(in thousands)

 2013

 2012

 2011

Cash flow before changes in operating assets and liabilities

 $

 149,848

 $

 338,713

 $

 454,380

Changes in operating assets and liabilities:

Receivables and other current assets

 663

 9,756

 (21,950

 )

Prepaid expenses and other

 (15,165

 )

 2,489

 (8,839

 )

Inventories

 4,031

 (48,305

 )

 (30,408

 )

Accounts payable and accrued liabilities

 (25,910

 )

 (31,019

 )

 22,990

CASH PROVIDED BY OPERATING ACTIVITIES

 $

 113,467

 $

 271,634

 $

 416,173

Cash provided by operating activities decreased $158.2 million in 2013 compared to 2012 primarily due to lower average realized silver and gold prices and lower silver ounces sold, partially offset by higher gold ounces sold, lower costs applicable to sales per gold ounce and a smaller increase to working capital.  2013 metal sales were $207.3 million lower due to lower average realized prices, partially offset by $57.8 million due to higher sales volumes.  Cash provided by operating activities decreased $144.6 million in 2012 compared to 2011 primarily due to a lower average realized silver price, lower silver and gold ounces sold, higher costs applicable to sales and a larger increase in working capital, partially offset by a higher average realized gold price.  2012 metal sales were $59.4 million lower due to lower average realized prices and $66.3 million lower due to lower sales volumes.

The Company’s financial position at December 31, 2013, and the expected operating cash flows over the next twelve months, lead management to believe that the Company’s liquid assets are sufficient to fund currently planned capital expenditures for existing operations and to discharge liabilities as they come due.  Please refer to the “Looking Forward” section of this MD&A for a more detailed description of capital expenditures planned for 2014.  The Company remains well-positioned to take advantage of strategic opportunities as they become available.

Overview of Mining Properties and Interests, page 3

Business Strategy and Competitive Strengths, page 8

Risk Factors, page 13 and 14

Argentina - Joaquin Mine, page 23 and 24

Looking Forward, page 32

Foreign Currency Contracts and Hedges, page 48

Note 10 - Acquisitions, page F-23

3.     We note you refer to the Joaquin and the La Preciosa properties as development stage properties at the above locations and elsewhere in your filing.  The terms development and production have very specific meanings within Industry Guide 7 (see www.sec.gov/about/forms/industryguides.pdf).  These words/terms reference the development stage when preparing reserves for production, and the production stage when companies are engaged in commercial-scale, profit-oriented extraction of minerals.  Since you do not disclose any reserves for these properties, as defined by Guide 7, please remove the terms develop, development or production throughout your document, and replace this terminology, as needed, with the terms such as explore or exploration.

The Company will remove in future filings the terms develop, development and production when referring to our Joaquin and La Preciosa projects and ensure all descriptive terms are in compliance with Industry Guide 7.  The Company does not believe the use of these terms in prior filings would be material to readers of the Company’s financial statements.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

4.   We note your royalty properties, Cerro Bayo, El Gallo/Magistral, and Zaruma are properties with reserves or mineralized materials that are not disclosed or updated in your filing.  Please modify your filing and provide updated reserve/mineralized material estimates for all your royalty properties, ideally to coincide with your fiscal year end.

The Company is pursuing a larger footprint in the royalty business, as demonstrated by the December 2013 acquisition of Global Royalty Corporation and reporting Coeur Capital as a new reportable segment at December 31, 2013.  The Coeur Capital segment includes the Company’s Endeavor silver stream and royalty properties.  Coeur Capital’s revenues and expenses are predominantly from the Endeavor silver stream for which all relevant reserve and production data is disclosed in the Company’s filings.  At December 31, 2013, royalty properties represented 1.9% of consolidated mining properties and 1.2% of consolidated assets.  At June 30, 2014, royalty revenue represented 0.6% of the Company’s consolidated revenue.  Given the limited nature of the Company’s royalty properties, management believes the general property description and disclosure of consolidated royalty revenue included in the Company’s filings to be appropriate from a quantitative and qualitative perspective.  The Company will continue to review and enhance its disclosures when appropriate as Coeur Capital’s portfolio grows.

5.   A portion of your revenues is dependent on the mine production that occurs at your royalty properties, but we note you do not report the silver or the funds received, nor do you report the tonnage and grade mined and/or processed at these respective properties, nor do you report the saleable metals on which your royalty revenues are based.  Please revise your filing to include detailed production information, saleable metals, and revenues received for each of your royalty properties.

We respectfully refer the Staff to the Company’s response to Comment No. 4.  Given the limited nature of the Company’s interest in royalty properties, management believes the revenue disclosures with respect to such properties to be appropriate from a quantitative

November 6, 2014

Via E -Mail
Mr. Mitchell J.  Krebs
Chief Executive Officer
Coeur Mining, Inc.
104 S. Michigan Avenue, Suite 900
Chicago, IL 60603

 Re: Coeur Mining, Inc.
  Form 10 -K for the Year Ended December 31, 2013
  Filed February 26, 2014
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your filing s and have the following comments.   In some of our
comments, 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  providing the requested
informatio n or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circumstances, please  tell us why in your response.

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

Form 10 -K for the  Year Ended December 31, 2013

Management’s Discussion and Analysis of Financial Condition  and Results of Operations, page
31
Critical Accounting Policies and Developments – Impairments, page 33

1. We note your disclosure under Note 4 that you recorded an impairment charge of
$773 million to mining properties in 2013.  Considering your impairment charges
and significant decline in your realized silver and gold prices during the periods
reported, to e nhance investor’s understanding regarding your recent impairment
testing of long lived assets, please confirm that you will disclose the following in
future filings:

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 2

  the amount of long -lived assets (mineral interests and property, plant and equipment)
allocated to each of the asset groups that are at risk of impairment and the percentage
by which fair value exceeded carrying value as of the date of the most recent test;

 a description of the methods and key assumptions used and how the key assumptions
were  determined;

 a discussion of the degree of uncertainty associated with the key assumptions  in as
specific a manner as p racticable ;

 the factors that affect variabi lity in the pricing assumptions ; and,

 a description of potential events and/or changes in circumstances that could
reasonably be expected to negatively affect the key assumptions.

Please provide us with a draft of your proposed disclosures.  Refer to FR -72, which can
be found on our website at : http://www.sec.gov/rules/interp/33 -8350.htm.

Liquidity and Capital Resources, page 40
Cash provided by operating activities, page 40

2. We note significant changes in your cash flows from operating activities during the
periods presented , for example, c ash provi ded by operating activities decreased by
$145 million and $158 million during 2012 and 2013 , respectively.  We note that
you have provided a general discussion for the reasons for the change.   However,
your discussions did not clearly identify the specific quantitative effect of the
underlying causal factors responsible for the change.  To enhance an investor’s
understanding, please confirm that in future filings you will include robust
discussions describing and quantifying the specific effect of the si gnificant drivers
that contributed to the material changes in your operating cash flows.  Please provide
us with a draft of proposed disclosures to be included in future filings.  Refer to Item
303 of Regulation S -K and SEC Release No. 33 -8350 as it relate s to liquidity and
capital resources for further guidance.

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 3

 Overview of Mining Properties and Interests, page 3
Business Strategy and Compet itive Strengths, page 8
Risk Factors, page 13 and 14
Argentina — Joaquin Mine, page 23 and 24
Looking Forward, page 32
Foreign Currency Contracts and Hedges, page 48
Note 1 0 – Acquisitions, page F -23

3. We note you  refer to the Joaquin and the La Preciosa  properties as development
stage properties at the above locations and elsewhere in your filing.  The terms
development and production have very specific meanings within Industry Guide 7
(see www.sec.gov/about/forms/industryguides.pdf).  These words/terms reference
the development stage when preparing reserves for production, and the production
stage when companies are engaged in commercial -scale, profit -oriented extraction of
minerals.  Since you do not disclose any reserves for these properties, as define d by
Guide 7, please remove the terms develop, development or production throughout
your document, and replace this terminology, as needed, with the terms such as
explore or exploration.

4. We note your royalty properties, Cerro Bayo, El Gallo/Magistral, and  Zaruma are
properties with reserves or mineralized materials that are not disclosed or updated in
your filing.  Please modify your filing and provide updated reserve/mineralized
material estimates for all your royalty properties, ideally to coincide with your fiscal
year end.

5. A portion of your revenues is dependent on the mine production that occurs at your
royalty properties, but we note you do not report the silver or the funds received, nor
do your report the tonnage and grade mined and/or processed at  these respective
properties, nor do your report the sal eable metals on which your royalty revenues are
based.  Please revise your filing to include detailed production information, sal eable
metals, and revenues received for each of your royalty properties.

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 4

 Form 8 -K filed June 23, 2014

Exhibit 99.1 – Press release dated June 23, 2014
Gold Stream Agreement with Franco -Nevada

6. You disclose that under the new gold stream agreement, the gold payable to Franco -
Nevada would be recorded as a reduction in revenue r ather than in costs applicable
to sales.  Please provide us with a summary analysis of the terms of the two
agreements and your basis for the difference in recognition (reduction in revenue
versus cost) and the specific accounting literature that supports your position.

Form 10 -Q for the Quarter Ended June 30, 2014

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
31
Highlights – Three months ended June 30, 2014, page 31

7. We note your disclosure regarding your decision to defer development at La
Preciosa.  Please address the following:

 Tell us whether you considered this decision or the results of the updated feasibility
study to be a triggering event for assessing impairm ent at June 30, 2014 and explain
the basis for your conclusion.  Please refer to FASB ASC 360 -10-35-21.

 Please expand your critical accounting policy disclosure in future filings to include
your impairment assessment and triggering event considerations su rrounding La
Preciosa’s deferment decision.   Considering the significant decline in your realized
silver and gold prices, to the extent La Preciosa is considered to be at risk of
impairment, disclose the results of impairment testing, methodology, significant
estimates and underlying assumptions.  Please provide us with a draft of proposed
disclosures to be included in future filings.

 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 the 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.

Mr. Mitchell J.  Krebs
Coeur Mining, Inc.
November 6, 2014
Page 5

  In responding to our comments, 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 securities laws of the United States.

 You may contact James Giugliano at (202) 551 -3319, or Raj Rajan at (202) 551 -3388, if
you have questions regarding comments on the financial statements and related matters.  You
may conta ct George Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering comments.

        Sincerely,

        /s/Tia L. Jenkins

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

January 9, 2014

Via E -Mail
Peter C. Mitchell
Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, IL 60603

Re: Coeur Mining, Inc.
 Form 10-K for the Year Ended December 31, 2012
Filed February 21, 2013
Form 10 -Q for the Quarter Ended September 30, 2013
Filed November 6, 2013
File No. 001 -08641

Dear Mr. Mitchell :

We have completed our review of your filings .  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s 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.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of  1934 and all applicable rules require.

Sincerely,

/s/Tia L. Jenkins

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

CORRESP
1
filename1.htm

		4Q13 CDE SEC Comment Letter

December 20, 2013

VIA EDGAR AND HAND DELIVERY

Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

Office of Beverages, Apparel, and Mining

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C.  20549

Re:

 Coeur Mining, Inc.

Form 10-K for the Year Ended December 31, 2012

Filed February 21, 2013

Form 10-Q for the Quarter Ended September 30, 2013

Filed November 6, 2013

File No. 001-08641

Dear Ms. Jenkins:

On behalf of Coeur Mining, Inc. (the “Company”), this letter responds to your letter, dated December 6, 2013 (the “Comment Letter”), regarding (i) the above-referenced Annual Report on Form 10‑K (the “Annual Report”), filed on February 21, 2013 and (ii) the above-referenced Quarterly Report on Form 10-Q (the “Quarterly Report”), filed on November 6, 2013.  Each comment of the Staff of the Division of Corporation Finance (the “Staff”) is set forth below, followed by the corresponding response.  For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter.  Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 40

Liquidity and Capital Resources, page 54

Cash Provided by Operating Activities, page 55

1.

 We note your use of a non-GAAP measure disclosed as “operating cash flow.” In future filings, please provide the disclosures required by Item 10(e) of Regulation S-K for this non-GAAP measure.

The Company confirms it will provide the disclosures required by Item 10(e) of Regulation S-K for all non-GAAP measures included in future filings.

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

Form 10-Q for the Quarter Ended September 30, 2013

2.

 Your average realized prices for silver and gold were $21.06 per ounce and $1,329 per ounce in the third quarter 2013, respectively, which are significantly decreased from the average realized prices of $30.92 per silver ounce and $1,665 per gold ounce in 2012. Please tell us whether you considered the decline in silver and gold prices to be a triggering event for mineral asset impairment testing pursuant to FASB ASC 360-10-35-21, and if so, please provide us with your impairment testing results for each mine considered. In your response, please tell us the estimated long-term silver and gold prices you used in your impairment testing in each of the mine.

The Company reviews all long-lived assets for recoverability, whenever events or changes in circumstances indicate that carrying amounts may not be recoverable, in accordance with FASB ASC 360.  Specifically, the Company reviews the financial performance of its mines in connection with the preparation of its financial statements for each reporting period and determines whether any triggering events indicate the carrying value of its mineral assets may not be recoverable.  While average realized prices declined in 2013, because of historical short-term volatility in silver and gold prices, the Company generally does not consider intra-period fluctuations in the spot price of silver and gold, or the average realized prices for its production in a given period, to be a triggering event for long-lived mining assets. In its September 30, 2013 review, the Company did not identify any triggering events and therefore, in accordance with FASB ASC 360, the Company did not conduct further impairment testing.

*    *    *

The Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the U.S. Securities and Exchange Commission (the “Commission”) from taking any action with respect to the filing and (iii) 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.

We would be pleased to address any further Staff comments or questions related to the above matters.  If the Staff wishes to discuss this letter at any time, please do not hesitate to contact Casey Nault, Vice President and General Counsel at (312) 489-5846 or Mark Spurbeck, Vice President, Finance at (312) 489-5863.

Very truly yours,

/s/ Peter C. Mitchell

Peter C. Mitchell

Senior Vice President and Chief Financial Officer

cc:      Mitchell J. Krebs, President and Chief Executive Officer

Casey M. Nault, Vice President and General Counsel

Mark Spurbeck, Vice President, Finance

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

Coeur Mining, Inc. | 104 S. Michigan Ave., Suite 900 | Chicago, Illinois 60603 | t: 312-489-5843 | f: 312-489-5897 | www.coeur.com

December 6, 2013

Via E -mail
Peter C. Mitchell
Chief Financial Officer
Coeur Mining, Inc.
104 S. Michigan Ave., Suite 900
Chicago, IL 60603

Re: Coeur Mining, Inc.
 Form 10-K for the Year Ended December 31, 2012
Filed February 21 , 2013
Form 10 -Q for the Quarter Ended September 30, 2013
Filed November 6, 2013
File No. 001 -08641

Dear Mr. Mitchell :

We have reviewed your filing an d have the following comments.  In some of our
comments, 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 pr ovide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the  Year Ended December 31, 2012

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 40
Liquidity and C apital Resources, page 54
Cash Provided by Operating Activities, page 55

1. We note your use of a non -GAAP measure disclosed as “ operating cash flow.”  In future
filings , please provide the disclosures required by Item 10(e) of Regulation S -K for thi s
non-GAAP measure.

Peter C. Mitchell
Coeur Mining, Inc.
December 6, 2013
Page 2

 Form 10 -Q for the  Quarter Ended September 30, 2013

2. Your average realized prices for silver and gold were $21.06 per ounce and $1,329 per
ounce in the third quarter 2013, respectively, which are significantly decreased from the
average realize d prices of $30.92 per silver ounce and $1,665 per gold ounce in 2012.
Please tell us whether you considered the decline in silver and gold prices to be a
triggering event for mineral asset impairment testing pursuant to FASB ASC 360 -10-35-
21, and if so, please provide us with your impairment testing results for each mine
considered.  In your response, please tell us the estimated long -term silver and gold prices
you used in your impairment testing in each of the mine.

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 the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny 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 comments, 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 securities laws of the United States.

You may contact Suying Li  at (202) 551 -3335 or Angela Halac  at (202) 551 -3398  if you
have questions regarding comments 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

February 22, 2013

Via E -mail
Mr. Mitchell J.  Krebs
Chief Executive Officer
Coeur d’Alene Mines Corporation
505 Front Avenue
Coeur d’Alene, I D 83814

 Re: Coeur d’Alene Mines Corporation
  Form 10 -K for Fiscal Year Ended December 31, 2011
  Filed February 23, 2012
  File No. 001 -08641

Dear Mr. Krebs :

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or 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 la ws of the United States.  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 the Securities Exchange Act of 1934 and all applicable rules require .

        Sincerely,

        /s/Tia L. Jenkins

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

CORRESP
1
filename1.htm

CORRESP

 February 20, 2013

 VIA EDGAR AND HAND DELIVERY

 Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

 Office of
Beverages, Apparel, and Mining

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
Coeur d’Alene Mines Corporation

 Form 10-K for Fiscal Year Ended December 31, 2011

 Filed
February 23, 2012

 Comment Letter dated February 6, 2013

File No. 001-08641

Dear Ms. Jenkins:

 On
behalf of Coeur d’Alene Mines Corporation Inc. (the “Company”), this letter responds to your letter, dated February 6, 2013 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10-K
(the “Annual Report”), filed on February 23, 2012. The comment of the Staff of the Division of Corporation Finance (the “Staff”) is set forth below, followed by the Company’s response. For ease of
reference, the headings and numbered paragraph below correspond to the headings and numbered comment in the Comment Letter. The response of the Company is set forth in ordinary type beneath the comment of the Staff appearing in bold type.

 Form 10-K for Fiscal Year Ended December 31, 2011

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 45

 Reconciliation of Non-GAAP Cash Costs to GAAP Production Costs, page 53

1.
 We note your response to our prior comment 5. We also note the significant effect of by-product credits to your silver cost per ounce and cash cost
per ounce measures computed using gold as a by-product. Accordingly, please modify your computation of these measures for the Palmarejo and Rochester mines so as not to include gold

as a by-product credit. Please also expand your disclosure to include the significant assumptions underlying your computation. In your response, tell us how you intend to present these measures
in future filings.

 Answer:

 The Company plans to file its next Form 10-K on or around February 21, 2013. The Company believes that continued presentation of cash costs per ounce including a by-product credit is useful to
readers of the financial statements for consistency and comparability purposes. The Company proposes to include substantially the following disclosure in its next Form 10-K and future Forms 10-K for the Palmarejo and Rochester mines as supplemental
disclosure to our by-product presentation of cash operating and total cash costs per ounce:

 “The low costs per silver
ounce are due in part to significant by-product credits from gold production and an increase in price over the last three years. For the years ended December 31, 20XX, 20XX and 20XX, gold by-product credits were approximately $XX.XX, $XX.XX and
$XX.XX per silver ounce, respectively, and were deducted from operating costs in the calculation of cash costs per ounce. If our accounting policy had been changed to treat gold production as a co-product, the following total cash costs per ounce
would have been reported:

20XX

20XX

20XX

 Cash operating cost per ounce:

 Silver

$
XX.XX

$
XX.XX

$
XX.XX

 Gold

$
 XXX

$
 XXX

$
 XXX

 Total cash cost per ounce:

 Silver

$
XX.XX

$
XX.XX

$
XX.XX

 Gold

$
 XXX

$
 XXX

$
 XXX”

 Further, the Company proposes to include substantially the following disclosure in its next Form 10-K and
future Forms 10-K to assist with the reconciliation of Non-GAAP cash costs per ounce to GAAP production costs on both a by-product and co-product basis:

 “Gold is accounted for as a by-product credit at the Palmarejo and Rochester mines whereby revenues from gold are deducted from operating costs in the calculation of cash costs per ounce. If our
accounting policy was changed to treat gold as a co-product, the following costs per ounce would be reported:

Palmarejo

Rochester

 Total cash operating costs

$
XXX,XXX

$
XXX,XXX

 Total cash costs

$
XXX,XXX

$
XXX,XXX

 Revenue

 Silver

XX
%

XX
%

 Gold

XX
%

XX
%

 Ounces produced

 Silver

X,XXX,XXX

X,XXX,XXX

 Gold

XXX,XXX

XXX,XXX

 Total cash operating costs per ounce

 Silver

$
 XX.XX

$
 XX.XX

 Gold

$
 XXX

$
 XXX

 Total cash costs per ounce

 Silver

$
 XX.XX

$
 XX.XX

 Gold

$
 XXX

$
 XXX”

 *        *        *

 The Company hereby acknowledges that: (i) the Company is responsible for the adequacy and accuracy of the disclosure in
the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the U.S. Securities and Exchange Commission (the “Commission”) from taking any action with respect to the filing and
(iii) 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.

If you have any questions regarding the above, please contact me at (208) 665-0770 or Andrew L. Fabens of Gibson, Dunn &
Crutcher LLP at (212) 351-4034. Please contact Elizabeth Druffel, the Company’s Treasurer and Chief Accountant, at (208) 665-0333 with regard to any accounting matters.

Very truly yours,

 /s/ Casey M. Nault

 Casey M. Nault

cc:
James Giugliano, Securities and Exchange Commission

Brian Bhandari, Securities and Exchange Commission

George Schuler, Securities and Exchange Commission

Mitchell J. Krebs, President and Chief Executive Officer

Frank L. Hanagarne, Jr., Senior Vice President, Chief Operating Officer and Chief Financial Officer

Donald J. Birak, Senior Vice President of Exploration

Elizabeth Druffel, Treasurer and Chief Accountant

Andrew L. Fabens, Gibson, Dunn & Crutcher LLP

February 6, 2013

Via E -mail
Mr. Mitchell J.  Krebs
Chief Executive Officer
Coeur d’Alene Mines Corporation
505 Front Avenue
Coeur d’Alene, I D 83814

 Re: Coeur d’Alene Mines Corporation
  Form 10 -K for Fiscal Year Ended December 31, 2011
  Filed February 23, 2012
  Response dated January 24 , 2012
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your response  and have the following comment .  In some of our
comments, 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 d o not believe our comment applies  to your facts and circumstances, or do not
believe an amendment is appropriate, please  tell us why in your response.

After reviewing any amendment to your filing and the  information you provide in
response to this comment , we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
45
Reconciliation of Non -GAAP Cash Costs to GAAP Production Costs, page 53

1. We note your response to our prior comment 5.  We also note the significant effect  of by -
product credits to your silver cost per ounce and cash cost per ounce measures computed
using  gold as a  by-product.  Accordingly, p lease modify your computation of these
measures for the Palmarejo and Rochester mines so as not to include gold as a by -product
credit.  Please also expand your disclosure to include the significant assumptions
underly ing your computation.  In your response, tell us how you intend to present these
measures in future filings.

Mr. Mitchell J.  Krebs
Coeur d’ Alene Mines Corporation
February 6, 201 3
Page 2

 You may contact James Giugliano at (202) 551 -3319, or Brian Bhandari at (202) 551 -
3390, if you have questions regarding comments on the financia l statements and related matters.
You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering comments.  Please contact me at (202) 551 -3871 with any other questions.

        Sincerely,

        /s/Tia L. Jenkins

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

CORRESP
1
filename1.htm

Correspondence

 January 24, 2013

 VIA EDGAR AND HAND DELIVERY

 Ms. Tia L. Jenkins

Senior Assistant Chief Accountant

 Office of
Beverages, Apparel, and Mining

 Division of Corporation Finance

 U.S. Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

Re:
Coeur d’Alene Mines Corporation

 Form 10-K for Fiscal Year Ended December 31, 2011

 Filed February 23,
2012

 Comment Letter dated January 9, 2013

File No. 001-08641

Dear Ms. Jenkins:

 On
behalf of Coeur d’Alene Mines Corporation Inc. (the “Company”), this letter responds to your letter, dated January 9, 2013 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10-K
(the “Annual Report”), filed on February 23, 2012. Each comment of the Staff of the Division of Corporation Finance (the “Staff”) is set forth below, followed by the corresponding response. For ease of
reference, the headings and numbered paragraphs below correspond to the headings and numbered comments in the Comment Letter. Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold
type.

 The Company respectfully requests to revise its disclosure prospectively. The Company believes this approach is
appropriate because the Company plans to file its next Form 10-K on or around February 21, 2013. Further, the proposed revisions contain only supplemental information that investors may find useful. The Company does not believe that the
revisions represent a material change from the Company’s prior disclosure or correction of a material error.

 Form 10-K for Fiscal Year Ended December 31, 2011

Silver and Gold Mining Properties, page 19

 USA – Nevada-Rochester Mine, page 28

1.
We note your response to comment 1 in which you discuss the status of your leased claims, provided the requested supplemental information, and indicated you will
revise the stated number of leased claims to 66 claims. Please include this discussion regarding your leased claims in your modified filing, comment on any historical right of way’s, if any, which facilitate access on your claims, and clarify
that the 81 claims specified in your lease agreements has been changed to the 66 claims as indicated in your response. Should you intend to address this issue in future filings, please make the request for filing prospectively and include your
proposed modified paragraphs, sections, or pages with your response.

 Answer:

The Company proposes to include substantially the following disclosure in its next Form 10-K and, if applicable, other future Forms 10-K:

 “Coeur Rochester held 541 U.S. Federal unpatented claims, of which 66 were under lease agreements, and
23 patented claims, totaling approximately 8,600 acres through August 2011. On September 1, 2011, the Company inadvertently missed a claims fee payment to the U.S. Bureau of Land Management (BLM) and as a result the prior unpatented mining
claims were forfeited. In December 2011, the Company located new claims on ground covered by the previous unpatented mining claims, including those subject to lease agreements. The new claims total 479 and cover the majority of the prior unpatented
claim area.

 With respect to the claims that were held under lease agreements, the Company has continued to
pay lease fees to the lessors according to the rates set forth in the lease agreements. The Company is not currently mining on any of these claims, and the Company does not believe these claims to be individually or collectively material to the
Company’s cash flows or the Rochester property’s current plan of operations approved by the BLM. The Company uses the property on which these claims are located principally to facilitate access to other portions of the Rochester property
and to provide space for infrastructure. None of the lessors has initiated or threatened any litigation against the Company with respect to the leases or the Company’s continued use of the lessors’ property.

A substantial portion of the new claims is the subject of a legal dispute stemming from competing asserted interests in
the claims. A third party asserts that it also staked and filed notices on the Company’s original unpatented mining claims. The Company believes it holds a superior property interest to the adverse staking party and filed a lawsuit to quiet
title in the claims. The mine operates under an approved BLM plan of operations and has continued normal operations

while the legal action is pending. The Company believes there would be no impact to the current silver and gold reserves at Coeur Rochester assuming an adverse outcome. Furthermore, the Company
believes that it would retain access to all active mining areas of the Rochester property notwithstanding an adverse outcome. Because surface access is governed by the approved BLM plan of operations and not by claim ownership, the Company believes
that it would retain surface access to all areas of property within the approved BLM plan of operations. However, the Company does believe an adverse outcome would cause it to modify existing plans to further expand future mining operations and
would require permits to be updated to reflect changes in claim ownership arising from an adverse outcome. See [Note 21 — Litigation and Other Events] for information relating to the unpatented mining claims dispute at Rochester.”

2.
We note you response to comment 2 in which you discuss the origin and effects of the preliminary injunction boundary, but did not provide the requested map as you
believe a map of the preliminary injunction boundary is not material to investors. We re-issue comment 2. Please include the preliminary injunction map in your filing showing the contested and uncontested mining claims, along with the website
address for the map in your revised filing.

 Answer: The Company proposes to include as an exhibit to
its next Form 10-K and, if applicable, other future Forms 10-K, the map of the preliminary injunction boundary attached to this letter as Exhibit A. In addition, the company proposes to include in such Forms 10-K a uniform resource locator (URL)
where the map may be accessed online.

3.
We note your response to comment 3 in which you respond that the mining operations at your Rochester mine have not been affected by the disputed claim ownership,
your leach dumps and stockpile expansions are not affected, and that in the event an adverse decision was rendered, the results could not be quantified. Please include this discussion in your modified filing.

Answer: The Company proposes to include substantially the following disclosure in its next Form 10-K and, if applicable, other
future Forms 10-K:

 “The claims dispute has not resulted in any changes to the Company’s
BLM-approved plan of operations for the Rochester property, or any effect on the Company’s leaching activities or stockpiles. The Company does not expect any such changes or effects unless the claims dispute is finally resolved against the
Company. In the event all claims in dispute were resolved in favor of Rye Patch, the Company cannot determine whether any fees or amounts would be awarded to Rye Patch for adverse land use, or what the amount or range of such fees or amounts might
be. However, the Company would not be subject to BLM fees for any such adverse land use within the BLM-approved plan of operations. The effect on the Company’s leaching operations or stockpiles could depend on further BLM proceedings or private
negotiations with respect to surface uses of the claims in dispute.”

 Year End Mineralized Material – Rochester Mine, page 30

4.
We note your response to comment 6, in which you state the affected tonnage and grade of mineralized material due the claim dispute and that you will include this
estimate in your future filings. Please revise your filing and include these estimates in your modified filing.

 Answer: The Company proposes to include substantially the following disclosure in its next Form 10-K and, if applicable, other future Forms 10-K:

“The Company estimates that approximately 65,383,000 short tons of mineralized material, containing 0.42 and 0.003
silver and gold ounces per ton, respectively, is affected by the claim dispute.”

 Management’s Discussion and Analysis of
Financial Condition and Results of Operations, page 45

 Results of Operations – Year Ended December 31, 2011 Compared
to Year Ended December 31, 2010, page 56

 Revenues, page 56

5.
We note your response to our prior comment 7. In accounting for gold production at Palmarejo and Rochester mines as a by-product, please tell us:

•

 how you account for gold inventory, including which costs are attributed to the gold produced and how those costs are carried in inventory
through production and processing;

•

 whether your units-of-depletion calculations exclude gold reserves and gold production and how depletion would be impacted by their
inclusion; and,

•

 an estimate of how co-product accounting would have impacted your cash cost per ounce of silver and gold (or gold in silver-equivalent ounces) for
2011 and for the nine months ended September 30, 2012.

 Answer: The Palmarejo and Rochester
mines account for gold inventories by utilizing an equivalent silver production approach. Gold production is converted to silver equivalent units using a ratio of the periodic average gold price to silver price. This result is added to the silver
production for use in distributing production costs to units in inventory. Production costs are then applied to each equivalent unit based on a weighted average cost.

 Units of depletion calculations at the Palmarejo and Rochester mines exclude gold reserves. Utilizing both the silver and gold reserves within the calculation of depletion results in no larger than a +/-
0.10% change in recognized depletion expense.

 The following table presents the estimated cash cost per ounce using both co-product and
equivalent ounce accounting for the Palmarejo and Rochester mines as compared to the by-product presentation for 2011 and the nine months ended September 30, 2012:

Nine Months ended
September 30,
2012

Year ended
December 31,
2011

Palmarejo

Rochester

Palmarejo

Rochester

 By-product (as reported):

 Cash operating cost per oz - silver

$
(0.12
)

$
12.75

$
(0.97
)

$
22.97

 Cash cost per oz - silver

(0.12
)

14.38

(0.97
)

24.82

 Co-product:

 Cash operating cost per oz - silver

9.14

19.44

12.82

25.34

 Cash cost per oz - silver

9.14

20.36

12.82

26.91

 Cash operating costs per oz - gold

680

1,136

581

1,050

 Cash cost per oz - gold

680

1,190

581

1,115

 Silver-equivalent:

 Cash operating cost per oz

10.32

20.13

12.91

25.05

 Cash cost per oz

10.32

21.08

12.91

26.60

 Notes to Consolidated Financial Statements, page F-8

Note 21 – Litigation and Other Events, page F-46

Unpatented Mining Claims Dispute at Rochester in Nevada, page F-47

6.
We note your response to our prior comment 8 did not address all aspects of our comment. In regards to the unpatented mining claims dispute at Rochester, please tell
us whether you believe the likelihood of a loss or impairment of assets is remote, reasonably possible or probable pursuant to FASB ASC 450-20 and the factors your consider in support of your conclusion.

Answer: The Company believes the likelihood of a loss or impairment of assets is remote for the following reasons:

•

 The Rochester property has continued normal operations while the claims dispute is pending. The Company has had, and continues to have, access to all
its facilities and infrastructure at the Rochester property.

•

 It is the Company’s view that under applicable legal authority, mining claims are interests in real property. Therefore, the Company believes, in
the event of an adverse legal determination with respect to ownership of any disputed mining claims, on the surface above which is located personal property of the Company, such as plant and equipment, the Company’s title to that personal
property would be unaffected.

•

 Property, plant and equipment is depreciated using either the straight-line method over the useful life of the individual asset, which is commensurate
with the life of the mine using current existing ore reserves, or the units-of-production method based on estimated total proven and probable ore reserves. Mining properties are depleted using the units-of-production method over the estimated life
of the ore body based on recoverable ounces to be mined from proven and probable reserves. The Company believes there would be no impact to the current silver and gold reserves at the Rochester property assuming an adverse outcome of the claims
dispute.

•

 The net amount of long-lived assets at Rochester as of December 31, 2011 and September 30, 2012 is $32.8 million and $37.0 million,
respectively. Operating cash flows before working capital changes for the nine months ended September 30, 2012 were $32.0 million on production of 2.0 million ounces of silver and 26,012 ounces of gold. The Company’s most recent
statement of reserves showed 29.6 million ounces of silver and 247,000 ounces of gold. Therefore, the Company believes that future cash flows will be sufficient to recover the book value of the long-lived assets.

*        *        *

 The Company hereby acknowledges that: (i) the Company is responsible for the adequacy
and accuracy of the disclosure in the filing; (ii) Staff comments or changes to disclosure in response to Staff comments do not foreclose the U.S. Securities and Exchange Commission (the “Commission”) from taking any action with
respect to the filing and (iii) 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.

If you have any questions regarding the above, please contact me at (208) 665-0770 or Andrew L. Fabens of Gibson, Dunn &
Crutcher LLP at (212) 351-4034. Please contact Elizabeth Druffel, the Company’s Treasurer and Chief Accountant, at (208) 665-0333 with regard to any accounting matters, and please contact Donald J. Birak, the Company’s Senior
Vice President of Exploration, at (208) 769-5083 with any technical questions relating to exploration comments.

 Very truly yours,

 /s/ Casey M. Nault

Casey M. Nault

cc:
James Giugliano, Securities and Exchange Commission

 Brian Bhandari, Securities and Exchange Commission

 George Schuler, Securities and
Exchange Commission

 Mitchell J. Krebs, President and Chief Executive Officer

Frank L. Hanagarne, Jr., Senior Vice President and Chief Financial Officer

Donald J. Birak, Senior Vice President of Exploration

 Elizabeth Druffel, Treasurer and Chief Accountant

 Andrew L. Fabens, Gibson, Dunn
& Crutcher LLP

 Exhibit A

January 9, 2013

Via E -mail
Mr. Mitchell J.  Krebs
President and Chief Executive Officer
Coeur d’Alene Mines Corporation
505 Front Avenue
Coeur d’Alene, Idaho 83814

 Re: Coeur d’Alene Mines Corporation
  Form 10 -K for Fiscal Year Ended December 31, 2011
  Filed February 23, 2012
  Response dated December 21, 2012
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your response  and have the following comments.   In some of our
comments, 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 comments apply to your facts and circumstances, or do not
believe an amendment is appropriate, please  tell us why in your response.

After reviewing any amendment t o your filing and the  information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

USA – Nevada -Rochester Mine, page 28

1. We note your response to comment 1 in which you discuss the status of your leased
claims, provided the requested supplemental information, and indicated you will revise
the stated number of leased claims to 66 claims.  Please include this discussion regarding
your leased claims in your modified filing, comment on any historical right of way’s, if
any, which facilitate access on your claims, and clarify that the 81 claims specified in
your lease agreements has been changed to the 66 claims as indicated in your response.
Should you intend to address this issue in future filings, please make the request for filing
prospectively and include your proposed modified paragraphs, sections, or pages with
your response.

Mr. Mitchell J.  Krebs
Coeur d’ Alene Mines Corporation
January 9, 201 3
Page 2

 2. We note you response to comment 2 in which you dis cuss the origin and effects of the
preliminary injunction boundary, but did not provide the requested map as you believe a
map of the preliminary injunction boundary is not material to investors.  We re -issue
comment 2.  Please include the preliminary inju nction map in your filing showing the
contested and uncontested mining claims, along with the website address for the map  in
your revised filing .

3. We note your response to comment 3 in which you respond that the mining operations at
your Rochester mine hav e not been affected by the disputed claim ownership, your leach
dumps and stockpile expansions are not affected, and that in the event an adverse
decision was rendered, the results could not be quantified.  Please include this discussion
in your modified f iling.

Year End Mineralized Material – Rochester Mine, page 30

4. We note your response to comment 6, in which you state the affected tonnage and grade
of mineralized material due the claim dispute and that you will include this estimate in
your future fili ngs.  Please revise your filing and include these estimates in your modified
filing .

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
45
Results  of Operations – Year Ended December 31, 2011 Compared to Year Ended December 31,
2010, page 56
Revenues, page 56

5. We note your response to our prior comment 7.  In accounting for gold production at
Palmarejo and Rochester mines as a by -product, please tel l us:
 how you account for gold inventory, including which costs are attributed to the gold
produced and how those costs are carried in inventory through production and
processing;
 whether your units -of-depletion calculations exclude gold reserves and gol d
production and how depletion would be impacted by their inclusion; and,
 an estimate of how co -product accounting would have impacted your cash cost per
ounce of silver and gold (or gold in silver -equivalent ounces) for 2011 and for the
nine months ended  September 30, 2012.

Notes to Consolidated Financial Statements , page F -8
Note 21 — Litigation and Other Events , page F -46
Unpatented Mining Claims Dispute at Rochester in Nevada, page F -47

6. We note your response to our prior comment 8 did not address all  aspects of our
comment.  In regards to the unpatented mining claims dispute at Rochester, please tell us

Mr. Mitchell J.  Krebs
Coeur d’ Alene Mines Corporation
January 9, 201 3
Page 3

 whether you believe the likelihood of a loss or impairment of assets is remote, reasonably
possible or probable pursuant to FASB ASC 450 -20 and the fa ctors your consider in
support of your conclusion.

 You may contact James Giugliano at (202) 551 -3319, or Brian K. Bhandari at (202) 551 -
3390, if you have questions regarding comments on the financial statements and related matters.
You may contact George  Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering comments.  Please contact me at (202) 551 -3871 with any other questions.

        Sincerely,

        /s/ Brian K. Bhandari for

        Tia L. Jenkins
Senior Assistant Chief Accountan t
Office of Beverages, App arel, and
Mining

CORRESP
1
filename1.htm

Correspondence

 [Letterhead of Coeur d’Alene Mines Corporation]

December 21, 2012

 VIA EDGAR AND HAND
DELIVERY

 Ms. Tia L. Jenkins

 Senior Assistant Chief Accountant

 Office of Beverages, Apparel, and Mining

Division of Corporation Finance

 U.S. Securities
and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:
Coeur d’Alene Mines Corporation

Form 10-K for Fiscal Year Ended December 31, 2011

Filed February 23, 2012

File No. 001-08641

 Dear
Ms. Jenkins:

 On behalf of Coeur d’Alene Mines Corporation Inc. (the “Company”), this letter
responds to your letter, dated November 28, 2012 (the “Comment Letter”), regarding the above-referenced Annual Report on Form 10-K (the “Annual Report”), filed on February 23, 2012. Each comment of the
Staff of the Division of Corporation Finance (the “Staff”) is set forth below, followed by the corresponding response. For ease of reference, the headings and numbered paragraphs below correspond to the headings and numbered
comments in the Comment Letter. Each response of the Company is set forth in ordinary type beneath the corresponding comment of the Staff appearing in bold type.

 Form 10-K for Fiscal Year Ended December 31, 2011

 Silver and Gold
Mining Properties, page 19

 USA – Nevada-Rochester Mine, page 28

1.
We note you disclose 53 unpatented mining claims which were subject to lease agreements at your Rochester mining operations. Please disclose the present status of
these mining claims, whether there are any legal disputes with the owners, and also provide to us courtesy copies of these mining claim lease agreements.

Answer:   After the Company became aware of its inadvertent failure to pay annual mining claim
maintenance fees, the Company located new claims on all ground covered by

unpatented mining claims that are the subject of the claims dispute, including those subject to lease agreements. The Company has continued to pay lease fees to the lessors according to the rates
set forth in the lease agreements. The Company is not currently mining on any of the claims subject to lease agreements. These claims are not individually or collectively material to the Company’s cash flows. Nor are these claims individually
or collectively material to the Rochester property’s current plan of operations approved by the U.S. Bureau of Land Management (the “BLM”). The Company uses the property on which the claims are located principally to facilitate access
to other portions of the Rochester property and to provide space for infrastructure. None of the lessors has initiated or threatened any litigation against the Company with respect to the leases or the Company’s continued use of the
lessors’ property.

 In response to the Staff’s comment, the Company is supplementally submitting under separate
cover copies of all lease agreements with respect to unpatented mining claims (collectively, the “Leases”). Pursuant to Rule 12b-4 of the Securities Exchange Act of 1934 as amended, the Leases are being provided to the Staff on a
supplemental basis only and are not to be deemed filed or deemed part of the Annual Report. The Company respectfully requests that the Staff return the Leases to the Company pursuant to Rule 12b-4 upon completion of its review. The Company requests
confidential treatment of the Leases pursuant to the provisions of 17 C.F.R. § 200.83.

 The Annual Report inadvertently
underreported the number of unpatented mining claims subject to lease agreements, which total 66. The Company believes that the total number of unpatented mining claims subject to lease agreements is not material; however, the Company intends to
revise this disclosure in future filings.

2.
Please describe the preliminary injunction boundary separating your mining operations from Rye Patch mining claims and explain how this boundary was determined.
Please discuss the purpose this boundary serves and whether it has any effect on your mining operations in the short and/or long term. Please include a map of your claim dispute property map with your filing.

Answer:   The preliminary injunction boundary surrounds all the Company’s current mining
operations at the Rochester property and was established to protect public safety by excluding Rye Patch personnel from all active mining and processing areas. As disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q, Rye
Patch is prohibited from entering areas within the preliminary injunction boundary. The preliminary injunction does not, however, limit the Company’s activities inside or outside of the preliminary injunction boundary. Accordingly, the Company
does not expect the limits of the preliminary injunction boundary to have a material effect on mining operations at the Rochester property under the current BLM-approved plan of operations. All of the Rochester property’s current mineral
reserves are located on uncontested or patented claims, and are within the preliminary injunction boundary.

 Because the
preliminary injunction boundary does not affect the BLM-approved plan of operations, the Company does not believe a map showing the boundary’s contours is material information required to be included in the Company’s periodic filings.
Although

the Company believes that the limits of the preliminary injunction boundary are not material information, the Company has made available on its web site a map showing the uncontested claims,
claims in dispute, location of mineral reserves and preliminary injunction boundary. The map may be accessed by visiting the Company’s web site at www.coeur.com and clicking on “Rochester Claims Dispute” on the “Rochester,
Nevada” page under the tab “Operations”.

 As disclosed in the Annual Report and subsequent Quarterly Reports on
Form 10-Q, the Rochester property has continued normal operations while the claims dispute is pending. The Company expects normal operations to continue throughout the duration of the claims dispute.

3.
Please identify and disclose any constraints on your present mining operations due to your Rochester mining claim litigation. Please disclose any changes to your
BLM-approved Plan of Operation in the short term due to this challenge in the unpatented claim ownership. Please disclose any leach and/or waste dumps restrictions in the short and/or long term and any potential fees for adverse land use.

 Answer:   As disclosed in the Annual Report and subsequent Quarterly
Reports on Form 10-Q, the Rochester property has continued normal operations while the claims dispute is pending. The Company has had, and continues to have, access to all its facilities and infrastructure at the Rochester property.

The claims dispute has not resulted in any changes to the Company’s BLM-approved plan of operations for the Rochester property, or
any effect on the Company’s leaching activities or stockpiles (referred to sometimes as “waste dumps”). The Company does not expect any such changes or effects unless the claims dispute is finally resolved against the Company. In the
event all claims in dispute were resolved in favor of Rye Patch, the Company cannot determine whether any fees or amounts would be awarded to Rye Patch for adverse land use, or what the amount or range of such fees or amounts might be. However, the
Company would not be subject to BLM fees for any such adverse land use within the BLM-approved plan of operations. The effect on the Company’s leaching operations or stockpiles could depend on further BLM proceedings or private negotiations
with respect to surface uses of the claims in dispute.

4.
In the event you are not successful with your Rochester mining claim litigation, please describe the effects and/or costs to your present mining operations, mine
life, and exploration activities.

 Answer:   The Company believes that an
adverse outcome of the claims dispute would not have a material effect on present mining operations at the Rochester property or the remaining 5-year life of the Rochester mine under the current BLM-approved plan of operations. As disclosed in the
Annual Report and subsequent Quarterly Reports on Form 10-Q, the Company believes there would be no impact to the current silver and gold reserves at the Rochester property assuming an adverse outcome of the claims dispute.

 As disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q, the Company
believes an adverse outcome would cause it to modify existing plans to further expand future mining operations. As an administrative matter, an adverse outcome would require the Company’s permits to be updated to reflect the changes in claim
ownership. In future filings, the Company intends to clarify that an adverse outcome would prevent the Company from future exploration in areas that are subject to any claims ultimately determined to be held by third parties.

5.
Please explain any major changes to your mining operations from your permitted plan of operations as approved by BLM. Please disclose whether you have access to all
your facilities and infrastructure. Please provide an estimate of the permitting modification duration, cost, and other challenges due to this litigation.

Answer:   As disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q, the
Rochester property has continued normal operations while the claims dispute is pending. The Company has had, and continues to have, access to all its facilities and infrastructure at the Rochester property.

As disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q, the Company believes an adverse outcome would require
its permits to be updated to reflect changes in claim ownership. The Company cannot predict whether additional permitting activities may be necessary or desirable, or the duration or costs of the permitting process. However, the Company does not
intend to engage in any permitting activities unless operations on areas considered for permitting would be economically viable in light of the permitting and operating costs.

 Year End Mineralized Material – Rochester Mine, page 30

6.
Please modify your filing and disclose the tonnage and grade of the mineralized material affected by your claim dispute.

Answer:   As disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q, the Company
believes there would be no impact to the current silver and gold reserves at the Rochester property assuming an adverse outcome of the claims dispute. The Company estimates that approximately 65,383,000 short tons of mineralized material, containing
0.42 and 0.003 silver and gold ounces per ton, respectively, is affected by the claim dispute. The Company intends to include the tonnage and grade of the mineralized material affected by the claim dispute in its future filings.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 45

Results of Operations – Year Ended December 31, 2011 Compared to Year Ended December 31, 2010, page 56

Revenues, page 56

7.
We note you account for gold sales from your silver mines as by-product revenue. Please tell us the following:

•

 Identify each mine for which gold sales are accounted for as a by-product;

•

 on a mine-by-mine basis, what amount and percentage of revenues were derived from gold, silver and other metals for 2011 and the nine months ended
September 30, 2012; and

•

 why you believe by-product accounting is appropriate and the point at which you would consider co-product accounting to be more appropriate.

 Answer:   Gold sales are accounted for in the financial statements as
Sales of metal in the Consolidated Statements of Operations and Comprehensive Income. Gold sales are treated as a by-product credit only for purposes of determining non-GAAP cash costs per ounce as disclosed in Management’s Discussion and
Analysis. In this disclosure, non-GAAP cash costs per ounce are reconciled to the U.S. GAAP financial statements.

 As
disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q, the Company accounts for gold sales as a by-product at its Palmarejo, Rochester and Martha mines.

 The following tables present the amounts and percentages of revenues derived from gold and silver for the year ended December 31, 2011 and the nine months ended September 30, 2012 (in thousands
except percentages):

Year Ended December 31, 2011

Palmarejo

San
Bartolomé

Kensington

Rochester

Martha

Endeavor

Total

 Silver revenue

$
315,343

$
267,502

$
—

$
48,309

$
12,678

$
18,737

$
662,569

 Gold revenue

197,754

—

151,186

9,022

669

–

358,631

 Total revenue

$
513,097

$
267,502

$
151,186

$
57,331

$
13,347

$
18,737

$
1,021,200

 Percentage silver revenue

61%

100%

0%

84%

95%

100%

65%

 Percentage gold revenue

39%

0%

100%

16%

5%

0%

35%

Nine Months Ended September 30, 2012

Palmarejo

San
Bartolomé

Kensington

Rochester

Martha

Endeavor

Total

 Silver revenue

$
213,754

$
140,951

$
—

$
52,617

$
12,168

$
16,077

$
435,567

 Gold revenue

148,975

—

67,950

36,539

532

—

253,996

 Total revenue

$
362,729

$
140,951

$
67,950

$
89,156

$
12,700

$
16,077

$
689,563

 Percentage silver revenue

59%

100%

0%

59%

96%

100%

63%

 Percentage gold revenue

41%

0%

100%

41%

4%

0%

37%

 The Company believes that classification of gold as a by-product is appropriate for its Palmarejo,
Rochester and Martha mines for the following reasons:

•

 These mines are in mining districts historically associated with silver;

•

 The Company’s exploration in such mining districts has been directed toward silver;

•

 The Company’s mining and metallurgist treatment methods target silver at these mines as the primary product;

•

 Silver contributes a higher proportion of revenue than any other metal and is expected to do so in the future;

•

 The Company disclosed in the Annual Report and subsequent Quarterly Reports on Form 10-Q the impact of gold as a by-product in its Reconciliation of
Non-U.S. GAAP Cash Costs to U.S. GAAP Production Costs; and

•

 The Company has historically presented these three mines as producers primarily of silver based on the original analyses that justified putting the
projects into production. The Company believes that consistency in disclosure is important to its investors.

The Company would consider co-product accounting to be more appropriate if any of the circumstances listed above were to change. The
Company notes that identification of co-products in non-U.S. GAAP cost-per-ounce disclosures is not common among other silver and gold mining companies.

 Notes to Consolidated Financial Statements, page F-8

 Note 21 –
Litigation and Other Events, page F-46

 Unpatented Mining Claims Dispute at Rochester in Nevada, page F-47

8.
We note you disclose that your inadvertent failure to pay annual mining claim maintenance fees resulted in a dispute regarding certain claims. In regard to these
developments, please tell us the following:

•

 the net amount of capitalized property, plant, equipment and development costs located on those disputed claims as of December 31, 2011 and
September 30, 2012;

•

 whether you believe the likelihood of a loss or impairment of assets is remote, reasonably possible or probable pursuant to FASB ASC 450-20; and

•

 whether you considered the lapse in the disputed claims to be a triggering event for impairment testing pursuant to FASB ASC 360-10-35-21, and if
so, provide us with the results of your impairment testing.

 Answer:
  The net amount of capitalized property, plant and equipment located on the surface covering the disputed claims and development costs associated with the disputed claims as of December 31, 2011 and September 30, 2012 is $1.7
million and $1.9 million, respectively. The Company has recorded all costs associated with the mineral resources on the disputed claims as Exploration expense in the Consolidated Statements of O

CORRESP
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filename1.htm

SEC Response Letter

 [Letterhead of Coeur d’Alene Mines Corporation]

December 5, 2012

 VIA ELECTRONIC MAIL

 Tia L. Jenkins

 Senior Assistant
Chief Accountant

 Office of Beverages, Apparel, and Mining

 Division of Corporation Finance

 United States Securities and Exchange Commission

100 F. Street, N.E.

 Washington, D.C. 20549-7010

Re:
SEC Comment Letter, dated November 28, 2012, with respect to Coeur d’Alene Mines Corporation, Form 10-K for Fiscal Year Ended December 31, 2011, Filed February
23, 2012, File No. 001-08641

 Dear Ms. Jenkins:

 This letter confirms that Coeur d’Alene Mines Corporation (the “Company”) received the November 28, 2012 comment letter of the Staff (the “Staff”) of the Securities and Exchange
Commission regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2011 (filed February 23, 2012).

 The
Company hereby requests that the Staff permit the Company to provide its response to the comments by December 21, 2012, which is seven business days after the originally requested response date.

We appreciate the Staff’s responsiveness with respect to the Company’s filing and look forward to resolving any concerns the Staff may have. If
you have any questions concerning this letter or the request for an extension, please contact me at (208) 699-6402 or Andrew L. Fabens of Gibson, Dunn & Crutcher LLP at (212) 351-4034.

 Very truly yours,

 /s/ Casey M. Nault

 Casey M. Nault

November 28, 2012

Via E -mail
Mr. Mitchell J.  Krebs
Chief Executive Officer
Coeur d’Alene Mines Corporation
505 Front Avenue
Coeur d’Alene, I D 83814

 Re: Coeur d’Alene Mines Corporation
  Form 10 -K for Fiscal Year Ended December 31, 2011
  Filed February 23, 2012
  File No. 001 -08641

Dear Mr. Krebs :

We have reviewed your filing  and have the following comments.   In some of our
comments, 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 comments apply to your facts and circumstances, or do not
believe an amendment is appropriate, please  tell us why in your response.

After reviewing any amendment to your filing and the  information you provide in
response to these comments, we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

Silver and Gold Mining Properties, page 19
USA – Nevada -Rochester Mine, page 28

1. We note you disclose 53 unpatente d mining claims which were subject to lease
agreements at your Rochester mining operations.  Please disclose the present status of
these mining claims, whether there are any legal disputes with the owners, and also
provide to us courtesy copies of  these mi ning claim lease agreements .

2. Please describe the preliminary injunction boundary separating your mining operations
from Rye Patch mining claims and explain how this boundary was determined.  Please
discuss the purpose this boundary serves and whether it h as any effect on your mining

Mr. Mitchell J.  Krebs
Coeur d’Alene Mines Corporation
November 28, 2012
Page 2

 operations in the short and/or long term.  Please include a map of your claim dispute
property map with your filing .

3. Please identify and disclose any constraints on your present mining operations due to
your Rochester mining c laim litigation.  Please disclose any changes to your BLM -
approved Plan of Operation in the short term due to this challenge in the unpatented
claim ownership.  Please disclose any leach and/or waste dumps restrictions in the short
and/or long term and an y potential fees for adverse land use .

4. In the event you are not successful with your Rochester mining claim litigation, please
describe the effects and/or costs to your present mining operations, mine life, and
exploration activities .

5. Please explain any major changes to your mining operations from your permitted plan of
operations as approved by BLM.  Please disclose whether you have access to all your
facilities and infrastructure.  Please provide an estimate of the permitting modification
duration, cost , and other challenges due to this litigation .

Year End Mineralized Material – Rochester Mine, page 30

6. Please modify your filing and disclose the tonnage and grade of the mineralized material
affected by your claim dispute .

Management’s Discussion and Analysis of Financial Condition and Results of Operations , page
45
Results of Operations - Year Ended December 31, 2011 Compared to Year Ended December 31,
2010 , page 56

Revenues, page 56

7. We note you  account for gold sales from your silver mines as by -product revenue.  Please
tell us the following:

 Identify each mine for which gold sales are accounted for as a by -product;

 on a mine -by-mine basis, what amount and percentage of revenues were derived f rom
gold, silver and other metals for 2011 and the nine months ended September 30,
2012; and

 why you believe by -product accounting is appropriate and the point at which you
would consider co -product accounting to be more appropriate.

Mr. Mitchell J.  Krebs
Coeur d’Alene Mines Corporation
November 28, 2012
Page 3

 Notes to Consolidate d Financial Statements , page F -8
Note 21 — Litigation and Other Events , page F -46
Unpatented Mining Claims Dispute at Rochester in Nevada, page F -47

8. We note you disclose that your inadvertent failure to pay annual mining claim
maintenance fees resulted in  a dispute regarding certain claims.  In regard to these
developments, please tell us the following:

 the net amount of capitalized property, plant, equipment and development costs
located on those disputed claims as of December 31, 2011 and September 30,  2012;

 whether you believe the likelihood of a loss or impairment of assets is remote,
reasonably possible or probable pursuant to FASB ASC 450 -20; and

 whether  you considered the lapse in the disputed claims to be a triggering event for
impairment testing pursuant to FASB ASC 360 -10-35-21, and if so, provide us with
the results of your impairment testing.

9. We note that an estimated 26% of measured and indicated resources and 41% of inferred
resources of the Rochester  mine are located within the disputed claims.  In this regard,
please tell us whether the loss of these claims would affect  either your undiscounted cash
flows used to test the asset for recoverabilit y or the discounted cash flows used to
measure the asset’s fair value including whether the cash flows associated with value
beyo nd proven and probable reserves  in estimates of future cash flows used for
determining whether your Rochester assets are impair ed.  Refer to FASB ASC 930 -360-
35-1.

 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 the Securities Exchange Act of
1934 and all applicable Exch ange 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 comments, please pr ovide 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

Mr. Mitchell J.  Krebs
Coeur d’Alene Mines Corporation
November 28, 2012
Page 4

  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.

 You may contact James Giugliano at (202) 551 -3319, or Brian Bhandari at (202) 551 -
3390, if you have questions regarding comments on the financial statements and related matters.
You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with questions about
engineering  comments.  Please contact me at (202) 551 -3871 with any other questions.

        Sincerely,

        /s/Tia L. Jenkins

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

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
        August 26, 2008

Mr. Mitchell Krebs
Chief Financial Officer Coeur d’ Alene Mines Corporation 505 Front Ave., P.O. Box “I” Coeur d’ Alene, ID  83816
 Re: Coeur d’ Alene Mines Corporation
  Form 10-K for Fiscal Year Ended December 31, 2007
Filed February 29, 2008 Schedule 14A Filed April 1, 2008 Response Letter Dated July 18, 2008 File No. 1-08641

 Dear Mr. Krebs:
We have completed our review of your Form 10-K and related filings and do not,
at this time, have any further comments.             S i n c e r e l y ,             H .  R o g e r  S c h w a l l          A s s i s t a n t  D i r e c t o r

CORRESP
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Mr.           H. Roger
Schwall
Assistant Director
U.S. Securities and Exchange Commission
Division of
Corporate Finance
100 F Street, N.E.
Mail Stop 7010
Washington, DC 20549

Re:
Coeur
d’Alene Mines Corporation
Form 10-K for Fiscal Year ended December 31, 2007
Filed
February 29, 2008
Schedule 14A Filed April 1, 2008
Comment Letter Dated July 11, 2008
File
No. 1-08641

July 18, 2008

Dear Mr. Schwall:

        I
am writing on behalf of Coeur d’Alene Mines Corporation (“Coeur” or the
“Company”) in response to the Staff’s letter of comments, dated July 11,
2008, regarding the Company’s Annual Report on Form 10-K for the year ended December
31, 2007 (the “Form 10-K”) which was filed on February 29, 2008, and the
Company’s Response Letter, dated June 23, 2008. Our responses reflect discussions
held during the telephone call we and our outside accountants and legal counsel had on
Thursday, July 17, 2008, with Ms. Jill Davis and Mr. Kevin Stertzel of the Staff. Set
forth below are the comments contained in your letter and the Company’s response
thereto.

Form 10-K for Fiscal Year
Ended December 31, 2007

Note E — Investments and
Other Marketable Securities, page F-19

1.
We
have reviewed your response to prior comment number four. Please explain why
          you determined the fair value of the ABCP based on your assessment of market
          conditions at the date of acquisition.

Mr. H. Roger Schwall
July 18, 2008

Page 2 of 7

Response:

        As
disclosed in the Company’s annual report on Form 10-K, the Company acquired these
asset- backed securities (ABCP) in connection with the acquisition of Palmarejo on
December 21, 2007. The Company recorded the securities, totaling $5.3 million, based on
its assessment of the fair value of the securities as of the purchase date. On December
31, 2007, the Company reviewed the carrying value of these investments and assessed
whether there were any changes in market conditions since the date of acquisition which
would impact the Company’s fair value assessment. No changes to the fair value
initially recorded were deemed necessary.

2.
Please
tell us which impairment model you are using under GAAP and expand your
          disclosure to address each of the following with respect to the ABCP.

•
The
key terms of security, including maturity dates, auction reset provisions, and interest
rate provisions

•
The
nature of the collateral, including an indication of credit quality

•
Describe
the cause of impairment, including a clarification of whether it was caused by credit
and/or liquidity issues

•
The
severity and duration of the impairment.

•
Indicate
whether underlying cash flows on the securities are being received

•
Describe
the valuation techniques used, including key assumptions

•
The
number and dollar value of failed auctions

•
Clarify
how and when principal will be available, such as, successful auctions occur, buyer found
outside auction process, maturity, redemption by issuer

Response:

        The
Company follows the guidance of FAS 115, Accounting for Certain Investments in Debt and
Equity Securities, and accounts for these investments as available for sale
securities. The amounts were classified as non-current assets at December 31, 2007, and
continue to be so classified today. The Company believes that the carrying value of these
investments is not material to the Company’s consolidated financial statements taken
as a whole and therefore additional disclosures in the footnotes are not warranted. The
Company will continue to assess the materiality of these investments and to the extent
they become material to the consolidated financial statements, the Company will provide
additional disclosure in future filings as required by GAAP.

Mr. H. Roger Schwall
July 18, 2008

Page 3 of 7

        As
requested, included below is information addressing each of the matters set forth above
in your comment:

•
The
key terms of security, including maturity dates, auction reset provisions, and interest
rate provisions

—
The original securities were invested in two trusts named Apsley Trust and Aurora Trust,
which carried interest rates of 5.035% and 4.27%, respectively. The trusts were originally
scheduled to mature in February and May 2008, respectively. The trusts underlying assets
mature from a few months to greater than 10 years for an overall average of approximately
9 years.

•
The
nature of the collateral, including an indication of credit quality

—
The underlying assets of the trusts include U.S. sub-prime mortgages, mortgage loans,
credit card debt and auto loans. DBRS, the rating agency, initially rated these securities
as AAA but down-graded its ratings, in the case of Apsley, in November 2007 and in the
case of all other trusts, early in 2008, due to their exposure to the U.S. sub-prime
credit markets.

•
Describe
the cause of impairment, including a clarification of whether it was caused by credit
and/or liquidity issues

—
Due to the overall credit crisis and a potential panic associated with the sub-prime
portion of the underlying assets collateralizing the notes, the liquidity providers were
concerned about their ability to cash out the trust investors. Consequently, the Trust
assets were frozen by the Montreal Accord and the activities of the Pan-Canadian Investors
Committee for Third-Party Structured Asset Backed Commercial Paper and the active trading
market was suspended.

•
The
severity and duration of the impairment

—
As noted above there is currently no active market and there has been no market since
trading in the trust assets was frozen in August 2007. The ABCP restructuring plan,
presented pursuant to the Companies’ Creditors Arrangement Act (“CCAA”),
was mailed to all noteholders on March 20, 2008 for a vote to be held on April 25, 2008.
The noteholders overwhelmingly approved the plan on April 25, 2008. Some noteholders,
opposing the release clauses (i.e. inability to sue any of the players involved with these
ABCP), challenged the legality of such clauses. The judge presiding over the CCAA
proceedings (from the Ontario Superior Court) agreed to hear arguments on the issue of the
release clause before providing his final judgment on the fairness of the restructuring
plan (as required under CCAA before the plan can be implemented). Hearings in front of
Justice Colin Campbell were heard on May 12 and 13. After going-back and forth between
investors and financial institutions to allow for limited recourse for fraud, Justice
Campbell approved the amended restructuring plan of the ABCP on June 5, 2008. Some
investors disagreeing with the limited extent of the release clause allowed by the amended
restructuring plan appealed the judge’s decision and presented their case to a
3-judge appeals court on June 25 and 26, 2008. The appeals court of Ontario has yet to
decide on whether or not to allow or to reject the arguments of the opposing investors. If
the appeals court allows the arguments, the opposing investors will have the ability to go
to the Supreme Court of Canada to argue their case, which will result in a further delay
in implementing the restructuring plan. If the appeals court rejects the arguments of the
opposing investors, the plan as approved by Justice Campbell will soon after be
implemented.

Mr. H. Roger Schwall
July 18, 2008

Page 4 of 7

•
Indicate
whether underlying cash flows on the securities are being received

—
Underlying assets of all of the instruments subject to the ABCP restructuring plan are
currently generating cash flows and cash accumulated to date approximates $12 billion.
Cash is not being distributed to note holders until resolution of the restructuring plan
as described above.

•
Describe
the valuation techniques used, including key assumptions

—
The Company used a discounted cash flow analysis over a nine year period using an interest
rate of 5.25%, which was the market rate for a 9 year AA rated debt instrument at the time
of the valuation.

•
The
number and dollar value of failed auctions

—
There are currently no auctions taking place, and none will occur until after resolution
of the restructuring plan as described above.

•
Clarify
how and when principal will be available, such as, successful auctions occur, buyer found
outside auction process, maturity, redemption

—
Upon approval of the restructuring plan, which would essentially consist of exchanging the
current paper with term floating rate notes (“FRNs”) with maturities based on
the maturities of the underlying assets, investors will be able to sell their investments.
As described above, the restructuring plan is currently in the Canadian Court system. It
is unknown when resolution will occur.

Mr. H. Roger Schwall
July 18, 2008

Page 5 of 7

Non-Producing and
Development Properties, page F-23

3.
We
note your response to prior comment five and continue to be unable to agree
          with your conclusion. It continues to appear that your political risk insurance
          premiums do not qualify for capitalization, and should be expensed as period
          costs. The cost of the policy benefits you over a specific period of time
          whether or not you are in the development or production stage. Once that period
          of time has passed the utility of the insurance premium that related to that
          period of time has lapsed. It does not extend the useful life, increase the
          earning capacity, or improve the efficiency or safety of your mine project. We
          note that this is further demonstrated by your conclusion that the premiums are
          expensed as incurred in the production stage. Accordingly it appears that the
          insurance premiums do not represent costs that can be capitalized, as they do
          not provide any future economic benefit, and therefore, do not meet the
          definition of an asset under CON 6. Please contact us if you would like to
          discuss this further.

Response:

        The
Company’s accounting policy is to capitalize costs directly identifiable to a mining
project in development. Incurred costs, including all forms of insurance, are capitalized
if they are direct and incremental; that is, the costs would not be incurred in absence of
the project. Absent the availability of political risk insurance coverage over the entire
expected mine life, the Company would not have made the decision to proceed to develop the
asset in Bolivia. The policy was entered into in December 2004 at the beginning of the
development stage of the project and has a twenty year term that runs through 2024, the
anticipated life of the project. Although the policy provides for annual premium payments,
the policy itself cannot be cancelled by the provider absent a breach by the Company.
Consequently, the Company believes the annual premium is a direct and incremental cost of
this facility and that it should be capitalized during the development phase of the
project consistent with other similar costs. In addition, to clarify the Company’s
previous response, the Company intends to treat the cost during the production phase as an
inventoriable cost and it will be expensed as the inventory is sold.

        In
forming its conclusion the Company has considered guidance addressing what costs are
required to be expensed as start-up by Statement of Position 98-5 Reporting on the Costs
of Start-up Activities (“SOP 98-5”) and which costs are to be excluded from
costs to be expensed as start-up costs.

        SOP
98-5 paragraph 05 states “For purposes of this SOP, start-up activities are
defined broadly as those one-time activities related to opening a new facility,
introducing a new product or service, conducting business in a new territory, conducting
business with a new class of customer or beneficiary, initiating a new process in an
existing facility, or commencing some new operation. Start-up activities include
activities related to organizing a new entity (commonly referred to as organization
costs).”

Mr. H. Roger Schwall
July 18, 2008

Page 6 of 7

        SOP
98-5, paragraph 12 states, “Costs of start-up activities including organization
costs, are to be expensed as incurred.” However SOP 98-5 paragraph 08 provides that
costs of acquiring or constructing long-lived assets and getting them ready for their
intended uses are outside the scope of the SOP. Paragraph 26 further recognizes
that the definition of start-up costs is imprecise. The SOP attempts to provide clarity to
start-up costs by presenting several example illustrations in the Appendix.

        Illustration
2 in the Appendix provides examples of costs incurred in conjunction with start-up
activities that are outside the scope of the SOP. One of the examples listed is,
“security, property taxes, insurance, and utilities costs related to
construction activities” (emphasis added). As described above, the political risk
insurance is directly related to the construction of the mine and development of the
mineral interest; therefore, the Company’s insurance cost is consistent with this
example and outside the scope of SOP 98-5. Accordingly, it is not required to be expensed
by this literature.

        The
logical extension of this conclusion is that since expensing is not required, the
determination of whether to expense or capitalize is judgmental and based on the facts and
circumstances of the situation. As described above, the Company would not have developed
this mine and the mineral interest without the political risk insurance policy.
Accordingly, it is logical to draw the conclusion that the insurance cost was a critical,
absolutely necessary, cost of developing the mine. Further, the coverage provided by this
insurance policy relates specifically to the Company’s Bolivia mine and provides no
coverage to any other part of the Company’s operations. For these reasons, the
Company concluded that the cost of this insurance is a direct and incremental cost related
to the development of the mine, and consistent with its accounting policy for costs
incurred during development stage of a mine, the Company has capitalized the cost of the
insurance policy that was incurred during the development stage. The Company believes this
accounting is appropriate and that it is supported by the accounting literature.

        The
Company has also considered that capitalizing political risk insurance costs are analogous
to the requirement to capitalize interest costs in that both of these costs are a cost of
acquiring the asset. In addition, the Company believes that the political risk coverage
has reduced its cost of funds significantly. This is supported by discussions the Company
had with underwriters of the financing, as well as the prominent display of the existence
of the coverage within the Company’s offering documents used in connection with the
financing of the project. Finally, the Company believes the policy enhances the value of
the project, since the policy attaches to the associated property and can be transferred
to a prospective buyer.

Mr. H. Roger Schwall
July 18, 2008

Page 7 of 7

Engineering Comment

4.
We
propose to have a telephone conference to discuss comment number 6 regarding
          the inclusion of inferred mineral resources in your disclosure of mineralized
          material at a date and time to be determined.

Response:

        The
Company looks forward to hearing from the Staff mining engineer regarding the schedule of
a conference call to discuss this comment.

********************************************************************************************************

        In
connection with the Company’s responses to the Staff’s comments set forth above,
the Company acknowledges that (i) the Company is responsible for the adequacy and accuracy
of the disclosure in the filing, (ii) Staff comments or changes to disclosure in response
to Staff comments do not foreclose the Com

CORRESP
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corresp

June 23, 2008

Mr. H. Roger Schwall

Assistant Director

U.S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Mail Stop 7010

Washington, DC 20549

    Re:

    Coeur d’Alene Mines Corporation

Form 10-K for Fiscal Year ended December 31, 2007

Filed February 29, 2008

Schedule 14A Filed April 1, 2008

Response Letter Dated May 14, 2008

File No. 1-08641

Dear Mr. Schwall:

     I am writing on behalf of Coeur d’Alene Mines Corporation (“Coeur” or the “Company”) in
response to the Staff’s letter of comments, dated June 12, 2008, regarding the Company’s Annual
Report on Form 10-K for the year ended December 31, 2007 (the “Form 10-K”), which was filed on
February 29, 2008, and the Company’s response letter, dated May 14, 2008. Set forth below are the
comments contained in your letter and the Company’s responses thereto.

     Underlined text indicates new disclosure added to address certain of the Staff’s comments.

Form 10-K for Fiscal Year Ended December 31, 2007

Financial Statements

Note B — Summary of Significant Accounting Policies

Metal and Other Inventory, page F-12

    1.

    We note your response to our prior comment number three. Please modify your disclosure to
indicate that the inventories associated with the Endeavor and Broken Hill mines are held by
third parties. Please quantify and present these inventories separately if material.

Mr. H. Roger Schwall

June 23, 2008

Page 2 of 8

    Response:

    Disclosure in response to this comment will be included in the second quarter 2008 Form 10-Q
to be filed no later than August 11, 2008, under Note B-Summary of Significant Accounting
Policies, Metal and Other Inventory, to clarify that the concentrate inventories associated
with silver sales transactions from the Endeavor and Broken Hill mines are held by third
parties. Concentrate inventories held by third parties associated with the Endeavor and
Broken Hill mines amounted to $175,000 and $165,000, respectively, at December 31, 2007 and
are included in the tabular disclosure in Note F as Concentrate and dorè inventory. Amounts
were deemed immaterial for separate disclosure. Similar disclosures will be included in
future Forms 10-K and Forms 10-Q, including separate disclosure of the dollar amounts if
they become material. The disclosure will read as follows:

    Metal and Other Inventory: Inventories include concentrate ore, dorè, ore in
stockpiles and operating materials and supplies. The classification of inventory is
determined by the stage at which the ore is in the production process. To the extent there
is work in process inventories at the Endeavor and Broken Hill mines, such amounts will be
carried as inventories . Inventories of ore in stock piles are sampled for gold and silver
content and are valued based on the lower of actual costs incurred or estimated net
realizable value based upon the period ending prices of gold and silver. Material that does
not contain a minimum quantity of gold and silver to cover estimated processing expense to
recover the contained gold and silver is not classified as inventory and is assigned no
value. All inventories are stated at the lower of cost or market, with cost being determined
using a weighted average cost method. Concentrate and dorè inventory includes product at the
mine site and product held by refineries and are also valued at lower of cost or market
value. Concentrate inventories associated with the Endeavor and Broken Hill mines are
held by third parties. Metal inventory costs include direct labor, materials,
depreciation, depletion and amortization as well as administrative overhead costs relating
to mining activities.

Operational Mining Properties, page F-12

    2.

    We note from your response to comment four from our letter dated April 30, 2008, that
drilling expenditures you incur at a producing mine to define and delineate residual mineral
deposits that have not been classified as proven and probable reserves are capitalized. As
there appears to be diversity in practice regarding the accounting treatment for such costs,
please expand your accounting policy disclosures to address the items below. In addition,
provide disclosure of the amounts that have been capitalized for the period and in total
relative to these costs for each period presented.

    •

    Expand your accounting policy for exploration and development costs to address the
criteria you use to determine whether or not a drilling expenditure represents an
exploration cost or a development cost.

    •

    Please indicate, if true, that your accounting for drilling costs depends upon
whether or not at the time the cost is incurred, the expenditure:

2

Mr. H. Roger Schwall

June 23, 2008

Page 3 of 8

    a.

    Embodies a probable future benefit that involves a capacity,
singly or in combination with other assets to contribute directly or indirectly
to future net cash inflows;

    b.

    You can obtain the benefit and control others access to it,
and,

    c.

    The transaction or event giving rise to your right to or
control of the benefit has already occurred.

    •

    Expand your accounting policy to explain how you determine whether or not you have
met the above criteria,

    •

    Clarify, if true, how the stage of mine development impacts whether or not
expenditure represents an asset.

    3.

    Your response to our prior comment number five remains unclear. Please clarify your
accounting for drilling and related costs incurred to identify additional resources, beyond
the boundaries of your known resources at your development or production stage properties.

    Response to #2 and #3:

    The Company will modify its disclosures in response to these comments in the second quarter
2008 Form 10-Q to be filed no later than August 11, 2008, under Note B-Summary of
Significant Accounting Policies, Operational Mining Properties and Mine Development, to
expand the disclosure of our accounting policy for drilling and related costs incurred to
update mineral resources to proven and probable reserves and our accounting treatment of
drilling and related costs incurred to identify additional resources at our development and
production stage properties.

    The disclosure will read as follows:

    Operational Mining Properties and Mine Development:

    Capitalization of mine development costs that meet the definition of an asset begins once
all operating permits have been secured, mineralization is classified as proven and probable
reserves and a final feasibility study has been completed. Mine development costs include
engineering and metallurgical studies, drilling and other related costs to delineate an ore
body, the removal of overburden to initially expose an ore body at open pit surface mines
and the building of access ways, shafts, lateral access, drifts, ramps and other
infrastructure at underground mines. Costs incurred during the start-up phase of a mine are
expensed as incurred. Costs incurred before mineralization is classified as

3

Mr. H. Roger Schwall

June 23, 2008

Page 4 of 8

    proven and probable reserves are expensed and classified as Exploration or Pre-development
expense. All capitalized costs are amortized using the units of production method over the
estimated life of the ore body based on recoverable ounces to be mined from proven and
probable reserves. Interest expense allocable to the cost of developing mining properties
and to construct new facilities is capitalized until assets are ready for their intended
use. Gains or losses from sales or retirements of assets are included in other income or
expense.

    Drilling and related costs incurred at our operating mines are expensed as incurred as
exploration expense, unless we can conclude with a high degree of confidence, prior to the
commencement of a drilling program, that the drilling costs will result in the conversion of
a mineral resource into proven and probable reserves. Our assessment is based on the
following factors: results from previous drill programs; results from geological models;
results from a mine scoping study confirming economic viability of the resource; and
preliminary estimates of mine inventory, ore grade, cash flow and mine life. In addition,
the Company must have all permitting and/or contractual requirements necessary to have the
right to and/or control of the future benefit from the targeted ore body. The costs of a
drilling program that meet these criteria are capitalized as mine development costs. All
other drilling and related costs, including those beyond the boundaries of the development
and production stage properties, are expensed as incurred.

    Drilling and related costs of approximately $xx and $xx, respectively, for the periods
presented met the criteria for capitalization listed above at our properties that are in the
production stage.

    The cost of removing overburden and waste materials to access the ore body at an open pit
mine prior to the production phase are referred to as “pre-stripping costs.” Pre-stripping
costs are capitalized during the development of an open pit mine. Stripping costs incurred
during the production phase of a mine are variable production costs that are included as a
component of inventory to be recognized in production costs applicable to sales in the same
period as the revenue from the sale of inventory.

Note E — Investments and Other Marketable Securities, page F-19

    4.

    We note your response to our prior comment number seven. Your representation of the
investment as of December 31, 2007 remains unclear. We further note your response indicates
the ABCP last traded in an active market on or about August, 13, 2007. We re-issue that
portion of our comment that requests you explain how you have classified (short-term vs.
long-term) the investment as of year end. Please provide support for your conclusions if you
are presenting this investment as a current asset at December 31, 2007.

4

Mr. H. Roger Schwall

June 23, 2008

Page 5 of 8

    Response:

    The Company has recorded the Asset-Backed Commercial Paper (“ABCP”) as a non-current asset
included in the “other” asset category on the Company’s consolidated balance sheet. This
classification as non-current is based on the timing of our intent and ability to utilize
those invested funds. The Montreal Proposal ABCP last traded in the active market on or
about August 13, 2007 and there are currently no market quotations available for the
Montreal Proposal ABCP. There is no certainty regarding the outcome of the Montreal Proposal
and therefore there is a significant amount of uncertainty in estimating the amount and
timing of cash flows associated with the Montreal Proposal ABCP. Accordingly, the Company
believes that the ABCP investment is appropriately recorded as a non-current asset.

    We note that the amounts for ABCP securities were not included in the table presentation of
the investments as of December 31, 2007 contained in Note E- Investments and Other
Marketable Securities. In future filings, the tabular disclosure of our investments will
include the ABCP amounts as non-current assets beginning with the second quarter 2008 Form
10-Q to be filed no later than August 11, 2008, and similar disclosures will be included in
future Forms 10-K and Forms 10-Q.

    The tabular disclosure will appear as follows:

    Gross

    Gross

    Unrealized

    Unrealized

    Estimated

    As of March 31, 2008:

    Cost

    Losses

    Gains

    Fair Value

    U.S. Corporate

    $
    2,000,000

    $
    —

    $
    —

    $
    2,000,000

    U.S. Government

    51,030,935

    —

    8,513

    51,039,448

    Total current
available for sale: Securities

    53,030,935

    —

    8,513

    53,039,448

    ABCP

    5,286,243

    —

    —

    5,286,243

    Equity Securities

    98,534

    355

    702,067

    800,247

    Total available for
sale securities

    $
    58,415,713

    $
    355

    $
    710,580

    $
    59,125,938

5

Mr. H. Roger Schwall

June 23, 2008

Page 6 of 8

Non-Producing and Development Properties, page F-23

    5.

    We note your response to our prior comment number nine. Please clarify for us the terms of
this policy. It remains unclear why this policy represents an asset beyond the period of
coverage. Your response indicates the policy provides coverage during the construction phase.
Please clarify if this policy is written for the entire construction phase or in shorter
increments. Also, please provide us with an understanding of your coverage, if any, during
the production phase.

    Response:

    The Company obtained a political risk insurance policy from Overseas Private Insurance
Corporation (“OPIC”) and another private insurer. The policy is in the amount of $155
million and covers 85% of any loss arising from expropriation, political violence or
currency inconvertibility. The coverage period started December 17, 2004 and extends
through December 16, 2024. The policy premiums are approximately $3.4 million per year. The
cost of this insurance policy is incremental to the Company’s other operations and is
directly related to the development, construction, and operation of the San Bartolome mine.
Therefore, consistent with our accounting policy of capitalizing direct and incremental
costs incurred during the development stage of our mines, we capitalized the costs of this
policy during the mine’s development stage; these costs represented the direct and
incremental cost of providing the necessary insurance coverage during that period. During
the production stage of the mine (which is expected to commence near the end of the second
quarter of 2008), the cost of this policy will be expensed as incurred.

Engineering Comments

    6.

    It appears that you are referring to the accommodation noted in Instruction 3 to paragraph
(b)(5) of Industry Guide 7, which is available to foreign companies and not to domestic
companies in your response to comment 12. The listing provisions of the Canadian and
Australian stock exchanges were developed by self regulated entities and as such are not
foreign law. Please modify your filing disclosure to remove your resource disclosures, and
ensure your disclosures of mineralized material do not include inferred resources.

    Response:

    Instruction 3 to paragraph (b)(5) of Industry Guide 7 states that:

    “Estimates other than proved (measured) or probable
(indicated) reserves . . . shall not be disclosed unless such information is required to be disclosed
by foreign or state law; provided, however, that where such estimates
previously have been provided to a person . . . that is offering . . . to
acquire the registrant’s securities, such estimates may be included.”

    Based on the above, mining resource data may be disclosed by Coeur if:

    •

    such data is required to be disclosed pursuant to foreign law; and/or

6

Mr. H. Roger Schwall

June 23, 2008

Page 7 of 8

    •

    such data previously has been disclosed by Coeur to another party that
offered to acquire Coeur’s securities.

    We respectfully submit that the plain English language contained in the above provision in
Guide 7 is not limited to foreign companies. It refers to “foreign or state law,” and has
no language supporting the proposition that the provision applies only to foreign companies.
(Indeed, inclusion of the word “state” in Instruction 3 makes even more clear what is
already clear — that the instruction applies to domestic corporations.)

    With respect to Canada, Coeur’s Canadian counsel has confirmed that Coeur is a reporting
issuer under the securities laws of the Canadian Provinces of Ontario, British Columbia and
Alberta (the “Canadian Securities Laws”), and is therefore subject to the requirements of
National Instrument 43-101, which has been adopted by each of those comm

CORRESP
1
filename1.htm

     Mitchell J. Krebs

     Senior Vice President and

     Chief Financial Officer

May 14, 2008

Mr. H. Roger
Schwall
Assistant Director
U.S.           Securities and Exchange Commission
Division of
Corporate Finance
100 F Street,           N.E.
Mail Stop 7010
Washington, DC 20549

RE:
Coeur
d’Alene Mines Corporation
Form 10-K for Fiscal Year ended December 31, 2007
Filed
February 29, 2008
Schedule 14A Filed April 1, 2008
File No. 1-08641

Dear Mr. Schwall,

        I
am writing on behalf of Coeur d’Alene Mines Corporation (“Coeur” or the
“Company”) in response to the Staff’s letter of comments, dated April 30,
2008, regarding the Company’s Annual Report on Form 10-K for the year ended December
31, 2007 (the “Form 10-K”) which was filed on February 29, 2008, and Schedule
14A (the “Proxy”) which was filed on April 1, 2008. Set forth below are the
comments contained in your letter and the Company’s responses thereto.

        Your
attention is directed to the Company’s Form 10-Q for the quarter ended March 31, 2008
filed on May 12, 2008 (the “Form 10-Q”) which addresses certain of those
comments as noted below.

        Underlined
text indicates new disclosure added to address certain of the Staff’s comments.

Coeur d’Alene Mines
Corporation
505 Front Avenue, P.O. Box I
Coeur d’Alene, Idaho 83816-0316
Telephone
208.667.3511
Facsimile 208.667.2213
www.coeur.com

Form 10-K for Fiscal Year
Ended December 31, 2007

Management’s
Discussion and Analysis of Financial Condition and Results of Operations

General

1.
Please
expand your discussion under this heading to include a meaningful           introduction
or overview. In this regard, we refer you to the Commission           Guidance Regarding
Management’s Discussion and Analysis of Financial           Condition and Results of
Operations (Release No. 34-48960). As examples only, if           material, discuss the
impact on future results of the possible sale of the           Rochester mine, the delay
in obtaining a permit for the tailings disposal           facility for the Kensington
mine, the increased costs and decreased production           at Cerro Bayo, and the
capital expenditures necessary to bring the Palmarejo           project into production
and the resulting impact on liquidity.

Response:

        Disclosure
in response to this comment was included in the Company’s MD&A in the Form 10-Q
for the quarter ended March 31, 2008 that was filed on May 12, 2008. Similar disclosures
also will be included in the MD&A section of the Company’s future Forms 10-K and
10-Q.

Insert
to 3/31/08 Form 10-Q:

        The
Company’s business strategy is to capitalize on the ore reserve/mineralized material
bases located at its operating mines and the expertise of its management team to continue
as a leading primary silver production company through long-term, cash flow generating
growth. The principal elements of the Company’s business strategy are to: (i) increase
the Company’s silver production and reserves; (ii) decrease cash costs and
increase production at the Company’s existing silver mining operations; (iii) transform
development-stage properties into producing mines; (iv) acquire operating mines,
mineral interests and exploration and/or development properties with a view to reducing
the Company’s cash and total costs, providing short-term positive cash flow return
and expanding its silver production base and reserves; and (v) continue to explore
for new silver and gold discoveries primarily near its existing mine sites and evaluate
new opportunities to expand its production through acquisitions and exploration.

        In
addition to the matters discussed above with respect to the key factors of the Company’s
business strategy, the most important matters with which management is concerned in
evaluating the Company’s financial condition and results of operations include:

•
Rochester
Mine. As scheduled, mining activities at Rochester ceased in August 2007 as the mine
entered its residual leaching  phase, which is expected to continue through 2011. The
Company continues to explore its options with respect to   this property, including a
potential sale of the property and possible follow-up activities related to any favorable
 results from the Company’s exploration program conducted in the district during
2007. The reduced production being   experienced in the residual leaching stage, and
ultimate cessation of activities there, will result in a reduction  in net sales.

•
Kensington
Mine. The Company continues to achieve major milestones in its effort to
enable the Kensington Mine to commence  production, including the completion of
Kensington’s mill, related surface facilities and a tunnel connecting the  Kensington
and Jualin properties. In addition, the Company continues to cooperate with environmental
conservation  groups with respect to the use of an alternative site for the
construction of the mine’s tailings disposal  facility. Further delay in the
commencement of production at the Kensington Mine would adversely affect the  Company’s
costs and liquidity.

•
Cerro
Bayo Mine. The Company’s top priority with respect to this mine is to
reduce operating costs and increase gold and  silver production. As part of the
ongoing operational improvement program at the Cerro Bayo mine, in April 2008,  the
Company announced a temporary suspension of mining operations at this mine, expected to
last approximately six  weeks, in order to upgrade its electrical infrastructure.
On May 5, 2008, the Company announced that the mine had  resumed operations ahead
of schedule. The continued successful implementation of the improvement program of Cerro
 Bayo will be key to achieving the Company’s goals of reducing costs and
increasing production at this mine.

•
Palmarejo.
In December 2007, Coeur completed the acquisition of the Palmarejo project. Capital
expenditures for this property are currently estimated to be approximately $225
million and construction activities there are already underway. The Company
currently expects to commence commercial production during the first half of 2009. Any
significant increase in the capital expenditures and/or delay in the commencement
of production would adversely affect the Company’s costs and liquidity.

•
San
Bartolome. The Company expects to commence commercial production at its open
pit silver development property in Bolivia  in the second quarter of 2008, and
estimates that initial full scale operating costs will approximate $4.10 per  ounce,
excluding royalties and production taxes. Other uncertainties associated with the project
include the  estimated amount of mineralized material there and logistical and
other risks associated with mining in Bolivia.  If  there is a delay in the
expected commencement of commercial production, or if operating costs prove to be higher
 than now estimated, the Company’s results of operations will be adversely
affected.

Financial Statements

Note B-Summary of
Significant Accounting Policies
Revenue Recognition, page F-10

2.
Please
expand your disclosure to clarify whether or not you are presenting           revenues
and costs associated with silver sales transactions from the Endeavor           and
Broken Hill mines gross or net. If you are reporting these transactions on a
          gross basis, please provide us with a detailed analysis which explains why
these           transactions require gross reporting. Please include in your analysis,
without           limitation, the specific terms of each agreement, an explanation of why
you           believe you are the primary obligor, and why you believe you take
possession of           the metals produced from these mines at any point in the earnings
cycle. Please           refer to and address EITF 99-19 in your response.

Response:

        The
Company has modified its disclosure in response to this comment in the first quarter 2008
Form 10-Q that was filed on May 12, 2008, under Note B: Summary of Significant Accounting
Policies, Revenue Recognition (page 7), to clarify that we are presenting revenues and
production costs associated with silver sales transactions from Endeavor and Broken Hill
mines on a gross basis as set forth below:

        In
2005, the Company acquired all of the silver production and reserves up to a maximum of
20 million payable ounces, at the Endeavor mine and 17.2 million payable ounces at the
Broken Hill mine. Under the terms of the agreements, title in the contained silver passes
to Coeur immediately after the contained silver becomes severed from the ground. We
obtained legal opinions from reputable counsel opining that the contained silver to be
mined pursuant to the agreements constitutes silver reserves under SEC Industry Guide 7,
as the requisite conditions have been met, including the fact that the Company has the
requisite incidents of ownership. The legal opinions also provide that pursuant to
Australia’s Mining Act, the incidents of ownership possessed by Coeur through the
agreements are economically and legally equivalent to the incidents of ownership that
Coeur would possess over silver reserves at a property owned and mined by Coeur.
Consequently, we have concluded that the Company possesses silver reserves, acts as
principal obligor, and assumes the risks and rewards of ownership and, therefore, we are
appropriately including these reserves in our reserve disclosures and appropriately
reporting the sold amounts as gross revenues. Pursuant to agreements with the operators
of these two mines, the Company pays a fee to the operators designed to reimburse them
for the cost of mining Coeur’s silver reserves.

        As
owner of the silver ore reserves at these two mines, the Company includes the silver
reserves at the Endeavor and Broken Hill mines in the silver reserves disclosures
reported by Coeur. In addition, Coeur reports sales of its silver from the Endeavor and
Broken Hill mines in its “Sales of Metal” line item on the statement of
operations, includes the quantities in its reported silver production amounts, and
includes the quantities and related costs in its “cost per ounce” calculations
and reported amounts. In addition, the Company depletes the purchase price paid to
acquire the silver reserves at the Endeavor and Broken Hill mines over the life of the
reserves using the units of production depletion method.

        We
have not performed an assessment of the provisions of EITF 99-19 because the Company
possesses the requisite incidents of ownership of the contained silver (as outlined
above) and is appropriately accounting for sales of the silver outside the scope of EITF
99-19.

        The
updated disclosure reads as follows:

        Revenue
Recognition: Pursuant to guidance in Staff Accounting Bulletin (“SAB”) No.
104, “Revenue Recognition for  Financial Statements”, revenue is
recognized, net of treatment and refining charges, from a sale when persuasive evidence
of  an arrangement exists, delivery has occurred, the price is fixed or
determinable, no obligations remain and collectability is  probable. The passing of
title to the customer is based on the terms of the sales contract. Product pricing is
determined at the point revenue is recognized by reference to active and freely
traded commodity markets, for example the London Bullion  Market for both gold and
silver, in an identical form to the product sold.

        Under
our concentrate sales contracts with third-party smelters, final gold and silver prices
are set on a specified future quotational period, typically one to three months, after
the shipment date based on market metal prices. Revenues and production costs
applicable to sales are recorded on a gross basis under these contracts at the
time title passes to the buyer based on the forward price for the expected
settlement period. The contracts, in general, provide for a provisional payment
based upon provisional assays and quoted metal prices. Final settlement is based on the
average applicable price for a specified future period, and generally occurs from
three to six months after shipment. Final sales are settled using smelter weights,
settlement assays (average of assays exchanged and/or umpire assay results) and are
priced as specified in the smelter contract. The Company’s provisionally
priced sales contain an embedded derivative that is required to be separated from
the host contract for accounting purposes. The host contract is the receivable from the
sale of concentrates measured at the forward price at the time of sale. The
embedded derivative does not qualify for hedge accounting. The embedded derivative
is recorded as a derivative asset, in prepaid expenses and other assets or as a derivative
liability in accrued liabilities and other on the balance sheet and is adjusted to fair
value through revenue each period until the date of final gold and silver
settlement. The form of the material being sold, after deduction for smelting and
refining is in an identical form to that sold on the London Bullion Market. The form of
the product is metal in flotation concentrate, which is the final process for
which the Company is responsible.

        The
effects of forward sales contracts are reflected in revenue at the date the related
precious metals are  delivered or the contracts expire. Third party smelting and
refining costs of $2.4 million and $1.8 million during the three  months ended
March 31, 2008 and 2007, respectively, are recorded as a reduction of revenue.

        At
March 31, 2008, the Company had outstanding provisionally priced sales of $61.0 million,
consisting of 2.7  million ounces of silver and 18,800 ounces of gold, which had a
fair value of approximately $64.7 million including the  embedded derivative. For
each one cent per ounce change in realized silver price, revenue would vary (plus or
minus)  approximately $27,000 and for each one dollar per ounce change in realized
gold price, revenue would vary (plus or minus)  approximately $18,800. At March 31,
2007, the Company had outstanding provisionally priced sales of $51.4 million, consisting
 of 2.8 million ounces of silver and 23,000 ounces of gold, which had a fair value
of approximately $52.5 million including  the embedded derivative.

        Similar
disclosures also will be included in future Forms 10-K and 10-Q.

3.
Please
expand your disclosure to indicate whether or not the silver purchased           under
these contracts is reported as inventory on your balance sheet.

Response:

        Consistent
with our response to comment # 2, the Company has modified its disclosure in response to
this comment in the first quarter 2008 Form 10-Q that was filed on May 12, 2008, under
Note B-Summary of Significant Accounting Policies, Metal and Other Inventory, (page 9) to
clarify that we are reporting concentrate inventories associated with silver sales
transactions from Endeavor and Broken Hill mines when, as of the balance sheet date, ore
has been mined but not yet sold to a third party smelter. Similar disclosures will be
included in future Forms 10-K and 10-Q.

        The
disclosure reads as follows:

        Metal
and Other Inventory: Inventories include concentrate ore, dorè, ore in
stockpiles and operating materials and supplies. The classification of inventory
is determined by the stage at which the ore is in the production process. To the extent
there is work in process inventories at the Endeavor and Broken Hill mines, such amounts
will be carried as inventories. Inventories of ore in stock piles
are sampled for gold and silver content and are valued based on the lower of actual
costs incurred or estimated net realizable value based upon the period ending prices of
gold and silver. Material that does not contain a minimum quantity of gold and
silver to cover estimated processing expense to recover the contained gold and
silver is not classified as inventory and i

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
        June 30, 2006

Mr. James A. Sabala
Chief Financial Officer
Coeur d’Alene Mines Corporation
505 Front Ave., P.O. Box “I”
Coeur d’Alene, ID 83816

 Re: Coeur d’Alene Mines Corporation
  Form 10-K for Fiscal Year Ended December 31, 2005
Filed March 14, 2006
File No. 1-08641

Dear Mr. Sabala:

We have completed our review of your Form 10-K and related filings and do not,
at this time, have any further comments.

        S i n c e r e l y ,

        Jill S. Davis
        B r a n c h  C h i e f

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
        June 20, 2006

Mr. James A. Sabala
Chief Financial Officer
Coeur d’Alene Mines Corporation
505 Front Ave., P.O. Box “I”
Coeur d’Alene, ID 83816

 Re: Coeur d’Alene Mines Corporation
  Form 10-K for Fiscal Year Ended December 31, 2005
Filed March 14, 2006
Form 10-Q for Fiscal Quarter Ended March 31, 2006
Filed May 9, 2006
Response letter dated May 22, 2006
File No. 1-08641

Dear Mr. Sabala:

We have reviewed your filings and response letter and have the following
comments.  We have limited our review of your filings to those issues we have addressed
in our comments.  Where indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

Form 10-Q for the Fiscal Quarter Ended March 31, 2006

Controls and Procedures, page 43

1. We note that you designed your disclosure controls and procedures to provide “reasonable assurance” of achieving the desired control objectives.  In future filings, please revise your conclusion to indicate, if true, that your disclosure controls and procedures are effective at the “reasonable assurance” level.  We note that your disclosure in your Form 10-K for the fiscal year ended December 31, 2005 indicated that your disclosure controls and procedures were effective at the reasonable assurance level.

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
June 20, 2006 Page 2

Engineering Comments

Form 10-K for the Fiscal Year Ended December 31, 2005

Silver and Gold Mining Properties, page 3

2. Revise your disclosure to include sufficient information in reserve tables for investors to figure the amount of minable reserves from the “in place” amounts that you disclose.  In most cases, this means including a footnote in each reserve table of the weighted average mining recover, if it does not already have that.

Australia - Endeavor Mine, page 12 and Australia – Broken Hill Mine, page 14

3. Your supplemental information indicates that the maximum amount of payable ounces of silver you have acquired at the Endeavor Mine exceeds the mine’s reserve estimates at this time.  Please disclose this information.  To the extent this condition also applies to the Broken Hill Mine, disclose that information.

Alaska – Kensington Gold Project, page 18

4. We note a significant change in your estimated capital costs for the Kensington project between your 2004 and 2005 Form 10-K filing.  In the latest filing, expand your disclosure about the reasons for this increase in capital costs, and compare the two estimates.

Closing Comments

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

 You may contact Jennifer Goeken at (202) 551-3721, Kevin Stertzel at (202) 551-
3723 or Jill Davis, Branch Chief, at (202) 551-3683 if you have questions regarding comments on the financial statements and related matters.  You may contact Roger Baer, Mining Engineer, at (202) 551-3705 with questions about engineering comments.  Please contact me at (202) 551-3740 with any other questions.

        S i n c e r e l y ,

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
June 20, 2006 Page 3

        H .  R o g e r  S c h w a l l
        A s s i s t a n t  D i r e c t o r

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

DIVISION OF
CORPORATION FINANCE MAIL STOP 7010
        May 9, 2006

Mr. James A. Sabala
Chief Financial Officer
Coeur d’Alene Mines Corporation
505 Front Ave., P.O. Box “I”
Coeur d’Alene, ID 83816

 Re: Coeur d’Alene Mines Corporation
  Form 10-K for Fiscal Year Ended December 31, 2005
Filed March 14, 2006
File No. 1-08641

Dear Mr. Sabala:

We have reviewed your filing and have the following comments.  We have
limited our review of your filings to those issues we have addressed in our comments.
Where indicated, we think you should revise your document in response to these comments.  If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may raise additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to working with you in these respects.  We welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
May 9, 2006 Page 2

Form 10-K for the Fiscal Year Ended December 31, 2005

Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 44

Critical Accounting Polices and Estimates

Reserve Estimates, page 45

1. We note your statement that “The Company reviews the carrying value of its assets whenever events or changes in circumstances indicate that the carrying amount of its assets may not be fully recoverable.  The Company did not record any write-downs during the years ended December 31, 2005, 2004 and 2003.”  Please elaborate on the last sentence given the line item entitled Write-down of mining properties and other holding costs presented within your consolidated statements of operations and comprehensive income (loss) for all years presented.

Operating Statistics and Reserve Estimates, page 48

2. We note your presentation of the tables reconciling between Non-GAAP cash costs per ounce to GAAP production costs on page 51 and the definitions of Cash Costs per Ounce and Cash Costs on page 52.  It appears that your measure for Cash Costs and Cash Costs per Ounce may be non-GAAP measures since you “exclude depreciation, depletion and amortization, corporate general and administrative expense, exploration, interest, and pre-feasibility costs and accruals for mine reclamation.”  In this regard, we believe that the most directly comparable GAAP measure would be fully  burdened with depreciation, depletion
and amortization related to the production of your products, consistent with SAB Topic 11:B.  Please support your reconciliation to the most directly comparable GAAP measure that excludes depreciation, depletion and amortization.

3. We further note that you may have excluded charges or liabilities that will require cash settlement or would require cash settlement absent an ability to settle in another manner with the exclusion of your accruals for mine reclamation.  Tell us and clarify within your disclosure whether these non-GAAP measures are liquidity or performance measures.  If you determine that these measures are liquidity measures, please tell us how you have complied with Item 10(e)(ii)(A) of Regulation S-K.

4. We note your reconciliation includes a line item for By-product credit.  Please expand your accounting policy to disclose how you classify by-product revenue and the amount of such revenue for each period reported.  Additionally, please

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
May 9, 2006 Page 3

expand your MD&A to clearly indicate that you generate by-product revenues on certain of your operating units and why you believe that presentation of these revenue streams as a by-product is appropriate.  Furthermore, include a trend analysis to identify the amount and type of by-product revenue generated for each period presented and indicate whether or not you believe, based on your best estimate, that presentation of these revenue streams as by-products will continue to be appropriate in the future.  Refer to Item 303(a)(3)(ii) of Regulation S-K for guidance.

Note B – Summary of Significant Accounting Policies, page F-10

Metal and Other Inventory, page F-12

5. We note your statement that “Concentrate and dorè inventory includes product at the mine site and product held by refineries.”  Please tell us how you account for the inventory held by refineries and any other off-site locations and which party retains legal title to the inventory when it is located at an off-site location.

Comprehensive Income (Loss), page F-16

6. Please revise your presentation of the components of other comprehensive income (loss) to comply with paragraph 25 of SFAS 130, which requires disclosure of the amount of income tax expense or benefit allocated to each component either on the face of the statement in which those components are displayed or in the notes to the financial statements.  Refer to paragraphs 24 and 25 of SFAS 130.

7. Please revise your presentation of the Change in fair value of cash flow hedges, net of settlements to comply with paragraph 47 of SFAS 133, which requires you to separately disclose the beginning and ending accumulated derivative gain or loss, the related net change associated with current period hedging transactions, and the net amount of any reclassification into earnings.

Note G- Long-Term Debt, page F-21

2004 Issuance of 1 ¼ % Convertible Senior Notes, page F-22

8. Please provide an analysis of the 1 ¼ % Convertible Senior Notes due 2024 that indicates whether or not, without limitation, the conversion option you disclose with respect to these notes should be bifurcated from the host and accounted for under the guidance in SFAS 133 and EITF 00-19.  Please tell us the guidance you have applied with respect to the debt host to support your current presentation.  You may wish to refer to guidance provided on the Division of Corporation Finance’s website concerning the classification and measurement of embedded

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
May 9, 2006 Page 4

conversion features, located at http://www.sec.gov/divisions/corpfin/acctdis120105.pdf.

Note S – Summary of Quarterly Financial Data (Unaudited), page F-43

9. We note your disclosure within footnote (b) that “Freight charges were previously misclassified and recorded as a reduction of sales of metal and have been reclassified to production costs applicable to sales.”  Please tell us whether or not this represents the correction of an error as defined in paragraph 13 of APB 20 or otherwise advise.

Engineering Comments

General

10. Please insert a small-scale map showing the location of each of your material properties.  See Item 102 (3)(B) of Regulation S-K.  Note that SEC’s EDGAR program now accepts digital maps; so please include these in any future amendments that are uploaded to EDGAR.  It is relatively easy to include automatic links at the appropriate locations within the document to GIF or JPEG files, which will allow the figures and/or diagrams to appear in the right location when the document is viewed on the Internet.  For more information, please consult the EDGAR manual, and if you need addition assistance, please call Filer Support at 202-942-8900.  Otherwise provide th e map to the engineering staff for
our review.

11. For each material property, ensure that the disclosures required by Industry Guide 7 (b) are included.  In particular, provide any conditions that you must meet in order to obtain or retain title to each material property.  Industry Guide 7 can be reviewed on the Internet at
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7 .

Silver and Gold Mining Operations, page 17

12. Proven and probable reserves are disclosed for the Cerro Bayo Mine and probable reserves for the San Bartolome property.  Forward to our engineer as supplemental information, information that establishes the legal, technical and economic feasibility of the materials designated as reserves, as required by Section C of SEC’s Industry Guide 7. This includes copies of feasibility studies or mine plans (including cashflow analyses), as well as pertinent engineering and geological reports concerning your property that are needed to establish the existence of reserves.  In particular, we would like to see the latest feasibility study for the San Bartolome property and the mine plan or life of mine plan for

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
May 9, 2006 Page 5

the Cerro Bayo Mine.  Provide drill hole and/or sampling maps for each property as is relevant.  Provide the name and phone number for a technical person our engineer may call, if he has technical questions about your reserves.

13. Provide as supplemental information, all reserve and/or resource audit reports that were produced for your mines and properties within the last three years,

14. In your reserve tables and narrative, disclose:

• Metallurgical recovery, currency conversion factors (when disclosing prices used) for estimate reserves, and mining recovery, if not included in estimate.
• The average drill spacing for each category of reserve, and for the mineralized material for each property.

15. Please indicate:

• What process and controls, if any, you have in place to assure that the materials being considered for classification as proven or probable by your staff or others, in different countries and locales, meet the SEC definitions of proven or probable reserves.
• Do you have an internal reserve review or “auditing” function within your company?  If so, describe who has this responsibility, and their functions and operation.
• Disclose the extent your reserve estimates have been reviewed by independent third parties.

Coeur Silver Valley, page 19

16. We note the higher costs the Galena mine incurred during 2005.  As supplemental information, provide a copy of your life-of -mine plan with cashflow analysis for
this mine.  Address the expected costs and continued economic recoverability of your disclosed reserves for the Galena mine.

Australia –Endeavor Mine, page 24 and Australia –Broken Hill Mine, page 26

17. Concerning the Endeavor and Broken Hill mines and as a supplemental response, provide the basis of your disclosure and a detailed explanation for the cash and total cash costs disclosed on page 25 for the Endeavor mine and page 26 for the Broken Hill mine.

18. Provide as supplemental material:

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
May 9, 2006 Page 6

• The original mineral reserve reports and any audits of that reserve that you used during your due diligence review of the Endeavor and Broken Hill mines, and any other reserve estimates or reserve/resource audits reports produced since that time.
• Complete copies of your purchase agreements for your interests in the Endeavor and Broken Hill mines.

19. As a supplemental response, provide a description and analysis of the following for both the Endeavor and Broken Hill mines:

• The extent of drilling and sampling of silver reserves.
• Geologic character and spatial distribution of recoverable silver.
• The extent of metallurgical characterization of the silver reserves to date.
• The metallurgical characteristics and variance of metallurgical characteristics between areas of the silver reserves.
• The correlation of silver recovery to lead recovery.
• The expected recoverability of silver, expected variance in silver recoverability, and overall reliability of your estimate of metallurgical recovery of silver.

20. Based on the provisions of your purchase agreements for the Endeavor and Perilya mines, as a supplemental response, address what incentives these companies have to maximize silver production, or to produce more than minimal quantities of silver.

Operating Statistics and Reserve Estimates, page 48

21. Concerning the Endeavor and Broken Hill mines and as a supplemental response, provide the basis and a detailed explanation for your credits for 2005 third party smelting costs for the Endeavor and Broken Hill mines on page 51.

Closing Comments

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provide us with a response.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendment and responses to our comments.

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
May 9, 2006 Page 7

  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 all information required under the Securities Exchange Act of 1934 and that they have provided all information investors require for an informed investment decision.  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 connection with responding to our comments, please provide, in writing, a 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 securities laws of the United States.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

 You may contact Jennifer Goeken at (202) 551-3721 or, in her absence, Kevin Stertzel at (202) 551-3723 if you have ques tions regarding comments on the financial
statements and related matters.  You may contact Mining Engineer Roger Baer at (202) 551-3705 with questions about engineering comments.  Please contact me at (202) 551-3740 with any other questions.

        S i n c e r e l y ,

        H .  R o g e r  S c h w a l l
        A s s i s t a n t  D i r e c t o r

CORRESP
1
filename1.htm

     FOLEY & LARDNER LLP

     WASHINGTON HARBOUR

3000 K STREET, N.W., SUITE 500

WASHINGTON, D.C.  20007-5143

202.672.5300  TEL

202.672.5399  FAX

www.foley.com

     March 9, 2006

     WRITER'S DIRECT LINE

202.295.4003

abill@foley.com  Email

     CLIENT/MATTER NUMBER

302010-0001

Ms. Jill S.
Davis
Branch Chief
U.S. Securities and Exchange Commission
Division of Corporation Finance

Mail Stop 7010
Washington, DC 20549

Re:
Coeur
d’Alene Mines Corporation
Item 4.02 Form 8-K
Filed March 2, 2006
File No. 1-8641

Dear Ms. Davis:

        We
are writing on behalf of Coeur d’Alene Mines Corporation (“Coeur” or the
“Company”) in response to the Staff’s letter of comments, dated March 7,
2006, regarding the Company’s Current Report on Form 8-K, filed March 2, 2006. Set
forth below are the comments contained in your letter and the Company’s responses
thereto.

Item 4.02 Form 8-K filed
March 2, 2006

1.
Please
tell us if your certifying officers have reconsidered the effect on the
          adequacy of your disclosure controls and procedures as of the end of the period
          covered by your Form 10-Q for the quarter ended March 31, 2005 in light of
          the error you have disclosed. Additionally, tell us what effect the error had
on           your current evaluation of disclosure controls and procedures as of your
fiscal           year ended December 31, 2005.

Response:

The
error was identified in connection with the 2005 year-end audit and was the result of an
inadvertent miscalculation of the quantity of ore tons delivered to the Company’s
Rochester Leach Pad in January 2005. The error resulted in a quarter-end inventory
understatement, an overstatement of production costs applicable to sales and an
overstatement of the net loss for the first quarter of 2005 in the amount of $625,000.
During the course of 2005, as a part of the Company’s SOX 404 deficiency remediation
process, the Company enhanced its control procedures at its operating units,
including requiring a completion of standard reporting packages for all significant
financial accounts. These financial reporting packages are reviewed by the Company’s
Assistant Controller and its Controller who double check the detail account
reconciliations and calculations related to the leach pad inventory. These new controls
would have detected the error had they been in place in the first quarter of 2005. Those
procedures were in place for all quarters subsequent to the first quarter of 2005 and
were tested and found to be functioning effectively. As a result, these controls were
deemed to have remediated the material weakness existing at March 31, 2005. Accordingly,
the Form 10-K for the year ended December 31, 2005, which we plan to file as soon as
practicable, will report under Item 9A that the certifying officers concluded that the
Company’s disclosure controls and procedures as of December 31, 2005 were effective.

BOSTON

BRUSSELS

CHICAGO

DETROIT

JACKSONVILLE

LOS ANGELES

MADISON

MILWAUKEE

NEW YORK

ORLANDO

SACRAMENTO

SAN DIEGO

SAN DIEGO/DEL MAR

SAN FRANCISCO

SILICON VALLEY

TALLAHASSEE

TAMPA

TOKYO

WASHINGTON, D.C.

WEST PALM BEACH

Ms. Jill S. Davis
U.S.
Securities and Exchange Commission
March 9, 2006
Page 2

The
Company’s certifying officers have reconsidered the effect of the adequacy of the
Company’s disclosure controls and procedures as of March 31, 2005 in light of the
adjustment that was reported in the Form 8-K. As explained in response to the Staff’s
next comment, the Company will file an amended Form 10-Q to restate the financial
statements for the first quarter of 2005. The Form 10-Q/A will report under Item 4 as a
result of the miscalculation that the Company’s certifying officers have concluded
that the Company’s disclosure controls and procedures were not effective as of March
31, 2005.

2.
Please
support your conclusion that you should not file an amended Form 10-Q for           the
quarter ended March 31, 2005 given your disclosure that “the interim
          financial statements previously set forth in the Company’s Quarterly
Report           on Form 10-Q for the quarter ended March 31, 2005 should no longer
be           relied upon.”

Response:

The
Company is filing an amendment to the Form 10-Q for the quarter ended March 31, 2005,
which will include restated financial statements for the quarter. Previously, the Company
had planned to include restated quarterly financial data in a footnote to the financial
statements in its Form 10-K for the year ended December 31, 2005. However, the Company
has now concluded that it will file a Form 10-Q/A
to set forth restated financial statements for the first quarter of 2005. Clean and marked copies
of the amendment will be delivered to the Staff at the time of filing to expedite its
review.

        In
connection with the Company’s responses set forth above, attached hereto is a
statement from the Company acknowledging that: (i) the Company is responsible for the
adequacy and accuracy of the disclosure in the above-referenced filing on Form 8-K; (ii)
Staff comments or changes to disclosure in response to Staff comments do not foreclose the
Commission from taking any action with respect to the above-referenced Form 8-K; and (iii)
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.

        Prior
to receiving your letter dated March 7, the Company had taken steps to proceed early next
week with an offering of common stock under its shelf Registration Statement. Accordingly,
we would greatly appreciate your prompt attention and assistance in the resolution of
this matter so that the offering can go forward early next week as previously planned.

Ms. Jill S. Davis
U.S.
Securities and Exchange Commission
March 9, 2006
Page 3

        Please
convey any comments or questions you have regarding the above to the undersigned at
202-295-4003 or Jay W. Freedman of this firm at 202-295-4008.

Sincerely,

/s/ Arthur H. Bill

Arthur H. Bill

cc:
Ms.
Jennifer Goeken

March 7, 2006

Ms. Jill S. Davis
Branch
Chief
United States Securities and Exchange Commission
100 F Street NE
Washington, DC
20549-7410

Re:
Coeur
d’Alene Mines Corporation
Item 4.02 Form 8-K
Filed March 2, 2006
File No. 1-8641

Dear Ms. Davis:

        In
response to your comment letter dated March 7, 2006, regarding the above Form 8-K of Coeur
d’Alene Mines Corporation (the “Company”), we acknowledge that:

•
the
Company is responsible for the adequacy and accuracy of the disclosures in the filing;

•
SEC
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.

Yours truly,

/s/ Dennis E. Wheeler

Dennis E. Wheeler
Chairman, President
and CEO

/s/ James A. Sabala

James A. Sabala
Executive Vice
President and CFO

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Str eet, NE
WASHINGTON, D.C. 20549-7010

DIVISION OF
CORP ORA TION FINANCE
MAIL STOP 7010
        March 7, 2006

Mr. James A. Sabala
Chief Financial Officer
Coeur d’Alene Mines Corporation
505 Front Ave., P.O. Box “I”
Coeur d’Alene, ID 83816

Re: Coeur d’Alene Mines Corporation
 Item 4.02 Form 8-K
Filed March 2, 2006
 File No.  1-8641

Dear Mr. Sabala:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comments, we may ask you to provide us with more information so we may
better understand your disclosure.  After reviewing this information, we may raise
additional comments.

 Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone number listed at the end of this letter.

Item 4.02 Form 8-K filed March 2, 2006

1. Please tell us if your certifying officers have reconsidered the effect on the adequacy of your disclosure controls and procedures as of the end of the period
covered by your Form 10-Q for the quarter ended March 31, 2005 in light of the
error you have disclosed.  Additionally, tell us what effect the error had on your

Mr. Jam es A. Sabala
Coeur d’Alene Mines Corporation
March 7, 2006
Page 2

current evaluation of disclosure controls and procedures as of your fiscal year ended December 31, 2005.

2. Please support your conclusion that you should not file an amended Form 10-Q for the quarter ended March 31, 2005 given your disclosure that “the interim
financial statements previously set forth in the Company’s Quarterly Report on
Form 10-Q for the quarter ended March 31, 2005 should no longer be relied upon.”

 As appropriate, please amend your filing and respond to these comments within
five business days or tell us when you will provide us with a response.  You may wish to
provide us with marked copies of the amendment to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed cover letters greatly facilitate our review.
Please understand that we may have additional comments after reviewing your
amendment and responses to our comments.

  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 all information required under
the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 connection with responding to our comments, please provide, in writing, a
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 securities laws of the United
States.

In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in our review
of your filing or in response to our comments on your filing.

 If you have any questions, please call Jennifer Goeken at (202) 551-3721.

Mr. James A. Sabala
Coeur d’Alene Mines Corporation
March 7, 2006
Page 3

       S i n c e r e l y ,

       Jill S. Davis
       B r a n c h  C h i e f