SecProbe.io

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 September 8, 2025

Elizabeth Senez
Chief Financial Officer
ENDEAVOUR SILVER CORP
# 1130-609 Granville Street
Vancouver
British Columbia
Canada V7Y 1G5

 Re: ENDEAVOUR SILVER CORP
 Form 40-F for the Fiscal Year Ended December 31, 2024
 Filed March 11, 2025
 File No. 001-33153
Dear Elizabeth Senez:

 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
 1
 filename1.htm

 Endeavour Silver Corp.: CORRESP - Filed by newsfilecorp.com

 August 29, 2025
 U.S. Securities and Exchange Commission
 Division of Corporation Finance
 Washington, D.C. 20549
 Attention: Ranjit Singh Pawar
 Re: Endeavour Silver Corp.
 Form 40-F for the Fiscal Year Ended December 31, 2024
 Filed March 11, 2025
 File No. 001 -33153
 Dear Mr. Pawar:
 On behalf of Endeavour Silver Corp (the "Company"), this letter responds to the comments of the Staff of the Securities and Exchange Commission (the "Staff") contained in your letter dated August 19, 2025 (the "Comment Letter") with respect to the above-referenced filing. For ease of reference, we have set forth each of the Staff's comments in bold type below, followed by the Company's response.

 Comment 1
 We note you disclose net earnings and comprehensive earnings for each of your reportable segments in the far-right column of your table at page 29. Please revise your disclosure to explain how you have allocated costs to your segments with details sufficient to understand the methods used and types of costs allocated to provide an understanding of the reported segment information. Refer to paragraph 27(b) of IFRS 8.
 Response:
 The Company acknowledges the Staff's comment. Beginning with our next Form 6-K for the quarter ending September 30, 2025, we will revise our disclosure to include the following wording to explain how we are allocating costs to our segments in accordance with IFRS 8.27:
 "Revenues, cost of sales, exploration costs and income taxes are attributed to the operation in which they arise. General and administrative costs, foreign exchange gains and losses, and investment and other income are managed centrally and are presented within the Corporate segment. Gains and losses from remeasurement of assets and liabilities measured at fair value are attributed to the segment in which the related asset or liability resides. Segment results are presented net of intersegment transactions where services are performed on behalf of other Group entities. There are no amounts unallocated to reportable segments."

 1

 Comment 2
 We note your disclosures related to the adverse tax ruling you received in June 2015 related to disputes between your subsidiary, MSCG and the Mexican tax authorities. We note that the tax assessment totaled $6.1 million and that subsequent efforts to appeal the matter have been rejected by the courts and that you are in discussions with the tax authorities to settle this estimated tax liability. Please explain your basis for recording $964 thousand accrual for this tax liability and the underlying guidance in IAS 12 that supports your accounting.
 Response:
 The $964 thousand accrual recognized in income taxes payable corresponds to the carrying amount of MSCG's net assets expected to be surrendered in a negotiated settlement at the reporting date. This amount represents what we expect to pay or surrender to the tax authority (in line with principles of IAS 12.46 and specific guidance of IFRIC 23.15). The accrual differs from the $6.1 million assessment because we do not expect to settle the full assessment. Based on legal advice, we anticipate that settlement will be achieved by transferring the shares of MSCG, rather than paying the full assessment amount. Consistent with IFRIC 23.8, no detection risk was included in the measurement.
 We will remeasure the accrual at each reporting date as negotiations advance or new information becomes available, with any changes recognized in income tax expense (IFRIC 23.13).

 Comment 3
 We note your discussion of the fair value hierarchy at Note 11(b) describes your specific assets and liabilities included in the Level 1, Level 2 and Level 3 categories and the inputs and valuation methods used to determine their fair values at page 34. Please revise your narrative disclosures to identify your derivative liabilities in the appropriate category.
 Response:
 The Company acknowledges the Staff's comment. Beginning with our next Form 40-F, we will revise our fair value hierarchy narrative disclosures as noted below to identify our derivative liabilities and assets in the appropriate category .
 "Level 2: The Company determines the fair value as follows: of the embedded derivatives related to the trade receivables based on the quoted closing price obtained from the silver and gold metal exchanges; SARs liability is determined by using an option pricing model; and the derivative liabilities by using forward prices from observable market curves for these contracts at the period end date."

 edrsilver.com

 2

 Closing
 We appreciate the Staff's comments and the opportunity to improve our disclosures. Please contact the undersigned at lsenez@edrsilver.com if you have any questions regarding our responses.
 Sincerely,

 Elizabeth Senez
 Chief Financial Officer
 Endeavour Silver Corp.

 edrsilver.com

 3

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 August 19, 2025

Elizabeth Senez
Chief Financial Officer
ENDEAVOUR SILVER CORP
# 1130-609 Granville Street
Vancouver
British Columbia
Canada V7Y 1G5

 Re: ENDEAVOUR SILVER CORP
 Form 40-F for the Fiscal Year Ended December 31, 2024
 Filed March 11, 2025
 File No. 001-33153
Dear Elizabeth Senez:

 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.

Form 40-F for the Fiscal Year Ended December 31, 2024
Exhibit 99.2
Consolidated Financial Statements for the Year Ended December 31, 2024
17. Segment Disclosures, page 29

1. We note you disclose net earnings and comprehensive earnings for each of
your
 reportable segments in the far right column of your table at page 29.
Please revise
 your disclosure to explain how you have allocated costs to your segments
with details
 sufficient to understand the methods used and types of costs allocated
to provide an
 understanding of the reported segment information. Refer to paragraph
27(b) of IFRS
 8.
 August 19, 2025
Page 2

18. Income Taxes, page 31

2. We note your disclosures related to the adverse tax ruling you received
in June 2015
 related to disputes between your subsidiary, MSCG and the Mexican tax
authorities.
 We note that the tax assessment totaled $6.1 million and that subsequent
efforts to
 appeal the matter have been rejected by the courts and that you are in
discussions with
 the tax authorities to settle this estimated tax liability. Please
explain your basis for
 recording $964 thousand accrual for this tax liability and the
underlying guidance in
 IAS 12 that supports your accounting.
19. Financial Instruments and Fair Value Measurements, page 34

3. We note your discussion of the fair value hierarchy at Note 11(b)
describes your
 specific assets and liabilities included in the Level 1, Level 2 and
Level 3 categories
 and the inputs and valuation methods used to determine their fair values
at page 34.
 Please revise your narrative disclosures to identify your derivative
liabilities in
 the appropriate category.
 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 Craig Arakawa at
202-551-
3650 if you have questions regarding comments on the financial statements and
related
matters.

 Sincerely,

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

United States securities and exchange commission logo
June 13, 2022
Christine West
Chief Financial officer
Endeavour Silver Corp.
# 1130-609 Granville Street
Vancouver
British Columbia
Canada V7Y 1G5
Re:Endeavour Silver Corp.
Form 40-F for the Fiscal Year Ended December 31, 2021
Filed March 10, 2022
File No. 001-33153
Dear Ms. West:
            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

CORRESP
1
filename1.htm

    Endeavour Silver Corp.: CORRESP - Filed by newsfilecorp.com

    June 3, 2022

    Via: EDGAR

    U.S. Securities & Exchange Commission

    Division of Corporation Finance

    100 F Street, NE

    Washington, D.C. 20549

    Attn: Craig Arakawa, Branch Chief

     Re:  Responses to the Securities and Exchange Commission

     Staff Comment Letter dated May 19, 2022

     Endeavour Silver Corp.

     Form 40-F for the Fiscal Year Ended December 31, 2021

     Filed March 10, 2022

     File No. 001-33153

    Ladies and Gentlemen:

    Endeavour Silver Corp. (the "Company") hereby respectfully submits this letter as response to the staff's comments set forth in the May 19, 2022 letter regarding the above-referenced Annual Report on Form 40F for the fiscal year ended December 31, 2021, as filed with the Securities and Exchange Commission ("SEC") on March 10, 2022 (File No. 001-33153).  For your convenience, the staff's comments are included below and we have numbered our responses accordingly.

    Our responses are as follows:

    Form 40-F for the Fiscal Year Ended December 31, 2021

    Exhibit 99.2 - Consolidated Financial Statements

    10. Mineral Properties, Plant and Equipment

    (e) El Cubo, Mexico, page 26

    1. Please tell us how you calculated the $16.8 million reversal of impairment related to El Cubo and explain how your calculation complies with paragraphs 122 and 123 of IAS36.

    Please ensure your response addresses the following:

        Provide the net book value of the impaired assets by type prior to the reversal

        Provide the net book value of these assets by type after reversal and the methods used to determine this amount

        Demonstrate how the post reversal amounts agree to the assets and liabilities held for sale reported as of March 31, 2021.

        Clarify how the $200.1 million related to depletion and depreciation factors into the calculation of the reversal and what it represents.

        1

    Company response:

    On March 17, 2022, a definitive agreement was signed to sell the El Cubo mine, plant and related equipment, including assumption of the asset retirement obligation, for consideration of $15.0 million, exclusive of any contingent consideration.  Upon the signing of the definitive agreement, the assets and liabilities were classified as held for sale and immediately prior to the classification, the El Cubo cash generating unit ("CGU") was remeasured.  At the time of remeasurement, the carrying value of the property, plant and equipment to be acquired was $1.2 million and the carrying value of the reclamation liability to be assumed was $4.6 million.

    IAS 36 paragraphs 122 & 123 require that the reversal of an impairment loss for a CGU be allocated to the assets of the unit, pro rata with the carrying amounts of those assets.  They also require that the carrying amounts of an asset not be increased above the lower of:

    (a) Its recoverable amount (if determinable); and

    (b) The carrying amount that would have been determined (net of amortization or depreciation) had no impairment loss been recognized for the assets in prior periods

    The method used to determine the amount to be reversed was the lower of the recoverable amount and the carrying amount that would have been determined had no impairment been recognized for the assets in prior periods.

    The recoverable amount of the El Cubo CGU was estimated to be $19.6 million, calculated as follows:

            Recoverable amount of the El Cubo CGU:

            Consideration per definitive agreement

            15,000,000

            Asset retirement obligation assumed on sale

            4,615,231

            Estimated cost to sell

            (500,000
            )

            19,615,231

    The following table details the net book value of the impaired assets prior to reversal:

            Gross amount

            Depn/ Depletion

            Net Book value before
reversal

            Surface rights and mine development

            81,181,435

            (81,181,435
            )
            -

            Plant

            10,785,141

            (9,791,862
            )
            993,279

            Buildings

            1,476,368

            (1,267,631
            )
            208,737

            Misc. Office equipment

            1,545,496

            (1,536,027
            )
            9,469

            94,988,440

            (93,776,955
            )
            1,211,485

        2

    The following table shows the hypothetical cost and accumulated depletion had no impairment been recorded

            Hypothetical Cost

            (net book value after

            Cost

            Depn/ Depletion

            reversal)

            Surface rights and mine development

            265,890,449

            (265,890,449
            )

            -

            Plant

            38,485,141

            (23,369,535
            )

            15,115,606

            Buildings

            5,876,368

            (2,998,660
            )

            2,877,708

            Misc. Office equipment

            1,645,496

            (1,636,027
            )

            9,469

            311,897,454

            (293,894,671
            )

            18,002,783

    The difference between the hypothetical cost and accumulated depreciation and the actual cost and accumulated depreciation prior to reversal is $216,909,014 and $200,117,716, respectively. The net of these two numbers of $16,791,298 is the amount available to be reversed.

    The sum of the net book value prior to reversal of $1,211,485 and the amount available to be reversed of $16,791,298 is $18,002,783.  As this amount is less than the recoverable amount of $19,615,231, the impairment amount available to be reversed of $16,791,298, was reversed.

    At March 31, 2021, the reported assets held for sale consist of the $18,002,783 net book value after reversal, reduced by the estimated costs to sell of $500,000.  The reported liabilities held for sale consist of the asset retirement obligation to be assumed on sale of $4,615,231.

    22. Segment Disclosures, page 39

    2. We note your disclosure at page 12 of Management's Discussion and Analysis indicated that you suspended operations at El Compas in mid-August 2021 as the mineral reserves at the mine were exhausted.  Please tell us why the underlying mineral property, plant and equipment balances related to El Compas have not been fully depleted as of December 31, 2021.

    Company response:

    As of December 31, 2021, the carrying value of the mineral property, plant and equipment balances related to El Compas were broken down as follows:

            Category

            Cost

            Accum Dep

            Net value

            Mineral Properties

            14,795,180

            (13,574,193
            )

            1,220,987

            Plant

            6,396,360

            (6,396,360
            )

            -

            Vehicles

            133,439

            (125,646
            )

            7,793

            Buildings

            669,664

            (129,237
            )

            540,427

            Office Furniture

            509,347

            (273,221
            )

            236,126

            22,503,990

            (20,498,657
            )

            2,005,333

        3

    For the mineral properties, all development costs were fully depleted and the residual balance of $1.2 million consists of owned land directly surrounding the mine area with a carrying value of $400K and $800K for acquisition costs for two brownfields exploration properties in the surrounding district, Veta Grande and Calicanto, which were each acquired for $400K.  The Company currently has a royalty agreement with Capstone Mining on the Calicanto agreement that is generating cash flow and will continue with exploration activities for these projects.

    The El Compas plant is fully depreciated and the Company maintains buildings, office equipment and vehicles to support care and maintenance and regional exploration activities.

    If you should have any further questions regarding our response letter, please do not hesitate to contact me at cwest@edrsilver.com or 604-861-1252.

    Sincerely,

    Endeavour Silver Corp.

    "Christine West"

    Christine West

    Chief Financial Officer

        4

United States securities and exchange commission logo
May 19, 2022
Christine West
Chief Financial officer
Endeavour Silver Corp.
# 1130-609 Granville Street
Vancouver
British Columbia
Canada V7Y 1G5
Re:Endeavour Silver Corp.
Form 40-F for the Fiscal Year Ended December 31, 2021
Filed March 10, 2022
File No. 001-33153
Dear Ms. West:
            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 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 40-F for the Fiscal Year Ended December 31, 2021
Exhibit 99.2 - Consolidated Financial Statements
10. Mineral Properties, Plant and Equipment
(e) El Cubo, Mexico, page 26
1.Please tell us how you calculated the $16.8 million reversal of impairment related to El
Cubo and explain how your calculation complies with paragraphs 122 and 123 of IAS36.
Please ensure your response addresses the following:
•Provide the net book value of the impaired assets by type prior to the reversal.
•Provide the net book value of these assets by type after reversal and the methods used
to determine this amount.
•Demonstrate how the post reversal amounts agree to the assets and liabilities held for
sale reported as of March 31, 2021.

 FirstName LastNameChristine West
 Comapany NameEndeavour Silver Corp.
 May 19, 2022 Page 2
 FirstName LastName
Christine West
Endeavour Silver Corp.
May 19, 2022
Page 2
•Clarify how the $200.1 million related to depletion and depreciation factors into the
calculation of the reversal and what it represents.
22. Segment Disclosures, page 39
2.We note your disclosure at page 12 of Management's Discussion and Analysis
indicates that you suspended operations at El Compas in mid-August 2021 as the mineral
reserves at the mine were exhausted.  Please tell us why the underlying mineral property
plant and equipment balances related to El Compas have not been fully depleted as of
December 31, 2021.
            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 Joanna Lam, Staff Accountant at 202-551-3476 or Craig Arakawa,
Branch Chief at 202-551-3650 if you have questions regarding comments on the financial
statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation

December 31, 2012

Via E -Mail
Bradford Cooke
Chief Executive Officer
Endeavour Silver Corp.
Suite 301 -700 West Pender Street
Vancouver, British Columbia
Canada V6C 1G8

Re: Endeavour Silver Corp.
 Form 40-F for Fiscal Year Ended December 31, 2011
Filed April 2, 2012
File No. 001 -33153

Dear Mr. Cooke :

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 laws of the Un ited 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 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

   Endeavour Silver Corp.: Correspondence - Filed by newsfilecorp.com

    Reply to:
    Dan Dickson

    Direct
      line:

    604-685-9775 x 236

    E-mail:
    ddickson@edrsilver.com

    File No.:
    001-33153

December 6, 2012

Division of Corporation Finance
United States Securities
and Exchange Commission
100 F Street, NE,
Washington, DC 20549

    Attention:
    Tia Jenkins, Senior Assistant

    Chief Accountant Office of Beverages,
      Apparel and Mining

Dear Sirs/Mesdames:

    Re:
    Endeavour Silver Corp. (“Endeavour”)

    Response to First Comments

    Form 40-F for Fiscal Year Ended December 31,
      2011

    Filed April 2, 2012

    File No. 001-33153

The following is Endeavour’s response to the Comment Letter
dated December 4, 2012.

    1.

      We note that you do not address the mandatory
      exceptions, as set forth in paragraphs 14-17 and Appendix B of IFRS 1 that
      you applied upon the adoption of IFRS. To the extent that your financial
      statements reflect the use of mandatory exceptions, please identify for us
      the items or class of items to which the exceptions were applied and
      describe the accounting principle that was used and how it was applied. In
      addition and to the extent material, also qualitatively describe for us
      the impact on the financial condition, changes in financial condition and
      results of operations that the treatment specified by IFRS would have had
      absent these mandatory exceptions. Refer to paragraph 23 of
  IFRS

The Company’s financial statements did not retrospectively
apply the IFRSs prior to the transition date (i.e. January 1, 2010) as required
by IFRS 1, paragraphs 14-17. Furthermore, no items or class of items fell within
the scope of the mandatory exceptions outlined in IFRS 1, paragraph B1.

Further, the Company understands it is responsible for the
adequacy and accuracy of the disclosure in the filing, staff comments or changes
to disclosure in response to staff comments does not foreclose the Commission
from taking any action with respect to the filing and the Company will not
assert staff comments as a defense in any proceedings initiated by the
Commission or any other person under the federal securities laws of the United
States.

Yours truly,

“Dan Dickson”

Dan Dickson
Chief Financial Officer

December 4, 2012

Via E -Mail
Bradford Cooke
Chief Executive Officer
Endeavour Silver Corp.
Suite 301 -700 West Pender Street
Vancouver, British Columbia
Canada  V6C 1G8

Re: Endeavour Silver Corp.
 Form 40-F for Fiscal Year Ended December 31, 2011
Filed April 2, 2012
File No. 001-33153

Dear Mr. Cooke :

We have reviewed your filing an d have the following comment.  In our comment , 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 comment a pplies  to your facts and circumstances, please tell
us why in your response.

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

Form 40 -F for Fiscal Year Ended December 31, 2011

Exhib it 99.2

Notes to the Consolidated Financial Statements

22. Transition to International Financial Accounting Standards

First time a doption of I FRS, page 30

1. We note that you do not address the mandatory exceptions, as set forth in paragraphs 14 -
17 and  Appendix B of IFRS 1 that you applied upon the adoption of IFRS. To the extent
that your financial statements reflect the use of mandatory exceptions, please identify for
us the items or class of items to which the exceptions were applied and describe the
accounting principle that was used and how it was applied.  In addition and to the extent

Bradford Cooke
Endeavour Silver Corp.
December 4, 2012
Page 2

 material, also qualitatively describe for us the impact on the financial condition, changes
in financial condition and results of operations that the treatment speci fied by IFRS
would have had absent these mandatory exceptions. Refer to paragraph 23 of IFRS 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 t he 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.

 In responding to our comment, 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 secur ities laws of the United States.

You may contact  Blaise Rhodes, Staff Accountant  at (202) 551 -3774  or Angela Halac  at
(202) 551 -3398  if you h ave questions regarding our comment  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

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628
       DIVISION OF
CORPORATION FINANCE

March 5, 2010

Via U.S. Mail & Facsimile

Mr. Dan Dickson Chief Financial Officer Endeavour Silver Corp. #301-700 West Pender Street  Vancouver, British Columbia Canada, V6C 1G8
Re: Endeavour Silver Corp.
Form 40-F for the Fiscal Year Ended December 31, 2008 Filed March 31, 2009, as Amended January 19, 2010 Response Letter Dated January 18, 2010
  File No. 1-33153

 Dear Mr. Dickson:
  We have completed our review of your filing and have no further comments at
this time.

Sincerely,

Anne Nguyen Parker Branch Chief

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4628
       DIVISION OF
CORPORATION FINANCE

December 31, 2009

Via U.S. Mail & Facsimile

Mr. Dan Dickson Chief Financial Officer Endeavour Silver Corp. #301-700 West Pender Street  Vancouver, British Columbia Canada, V6C 1G8
Re: Endeavour Silver Corp.
Form 40-F for the Fiscal Year Ended Dec. 31, 2008 Filed March 31, 2009
  File No. 1-33153

 Dear Mr. Dickson:

We have reviewed your filing and have the following comments.  Please provide
a written response to our comments.  Pleas e 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 re view 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.

Controls and Procedures, page 5

Changes in Internal Control Over Financial Reporting, page 7

1. We note your statement that “[e]xcept for the changes discussed above, there have been no changes that . . . materially affect ed, or are reasonably likely to materially
affect, the Company’s internal control ove r financial reporting.”  Revise to state
clearly that there were changes in your in ternal control over financial reporting

Mr. Dan Dickson
Endeavour Silver Corp.
December 31, 2009 Page 2

that occurred during this period that have materially affected, or are reasonably
likely to materially affect, your internal control over financial reporting.  In this
regard, we reissue comment 3 from our letter dated September 23, 2008.

Contractual Obligations, page 11

2. We note your disclosure of $1.4 billion in “Other Long-Term Li abilities.”  Please
revise to disclose the major components constituting this cat egory of obligation
and the corresponding amounts that you are obligated to pay.
 Closing Comments

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 a ny action with respect to the filing;
and

‚ the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

Mr. Dan Dickson
Endeavour Silver Corp. December 31, 2009 Page 3

Please contact John Lucas at (202) 551-5798 or, in his absence, me at (202) 551-
3611 with any questions.

Sincerely,

Anne Nguyen Parker Branch Chief

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
       DIVISION OF
CORPORATION FINANCE
        MAIL STOP 7010
October 24, 2008

Bradford Cooke Chairman and CEO Endeavour Silver Corp. #301-700 West Pender Street  Vancouver, British Columbia Canada, V6C 1G8
Re:  Endeavour Silver Corp.
Annual report on Form 40-F for the fiscal year ended Dec. 31, 2007
Filed April 7, 2008, as amended October 10, 2008
  File No. 1-33153

 Dear Mr. Cooke:

We have completed our review of your Form 40-F and have no further comments
at this time.

Sincerely,

Anne Nguyen Parker Branch Chief
   cc: J. Lucas  Kenneth G. Sam, Esquire (303) 629-3450

CORRESP
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        October 10, 2008

                        Via: First Class Mail and EDGAR

                        Securities and Exchange Commission

                        Division of Corporate Finance

                        Mail Stop 7010

                        100 F Street, NE

                        Washington, D.C. 20549

                        Attention: Mrs. Anne Nguyen Parker

                        Re:

                        Responses to the Securities and Exchange Commission

        Staff Comments dated September 23, 2008, regarding

        Endeavour Silver Corp.

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

        Filed April 7, 2008

        File No. 001-33153

        Ladies and Gentlemen:

        Endeavour Silver Corp. (the “Company”) hereby respectfully submits this letter as response to the staff’s comments set forth in the September 23, 2008 letter regarding the above-referenced Annual Report on Form 40-F for the fiscal year ended December 31, 2007, as filed with the Securities and Exchange Commission (“SEC”) on April 7, 2008 (File No. 001-33153). For your
        convenience, the staff’s comments are included below and we have numbered our responses accordingly.

        In some of the responses, we have agreed to change or supplement the disclosures in amendments to filings. We are doing so in the spirit of cooperation with the staff of the SEC, and not because we believe our prior filing is materially deficient or inaccurate. Accordingly, any changes implemented in these filings should not be taken as an admission that prior disclosures were in any way
        deficient.

        Our responses are as follows:

        Form 40-F for the fiscal year ended December 31, 2007

        Cover Page

        Staff Comment No. 1.

        Please update the address of your agent for service of process in the United States to include the agent’s city, state and zip code.

        Company Response:

        We have updated the information requested on the amended annual report on Form 40-F/A filed concurrently herewith.

        Management Report on Internal Control Over Financial Reporting, page 5

        Staff Comment No. 2.

        Please revise to describe the events surrounding the determination that you did not maintain effective internal control over financial reporting, including who identified the weaknesses and when the material weaknesses first began. Include dates of corrective actions and any associated material costs. Finally, with respect to future actions that will be taken to remediate the weakness, disclose when they
        are to occur and any associated material costs. Please be sure to address when you intend to take corrective action with respect to communicating employees’ duties over financial reporting

        Company Response:

        The Company has revised its annual report on Form 40-F for the period ended December 31, 2007 highlighting whether management or the external auditors identified the deficiency. The control environment deficiency and information and communication deficiency were identified by management through our assessment of internal control, while the foreign exchange deficiency and income tax deficiency were
        identified as a result of external auditor substantive audit procedures and subsequent re-assessment of the corresponding control process. The foreign exchange deficiency was a single occurrence of a currency conversion error of one account within the accounting software and the failure of the Company’s secondary controls to identify the error. The income tax deficiency was related to the insufficient internal expertise to appropriately account for the foreign income tax provision
        due to the complexity of new income tax laws introduced within the jurisdiction of our foreign subsidiaries.

        Although management has determined the deficiencies arose within the 2007 fiscal year, it has proved to be difficult to define any specific timeline when certain deficiencies first began. Given that it is the Company’s first time reporting on internal control over financial reporting, coupled with the characteristics of the control deficiencies, management has determined it can not adequately
        provide detailed disclosure as to when the deficiencies first occurred. The significant company growth coinciding with staff turnover contributed to authorized expenditure limits being insufficiently defined and communicated and the failure to implement new policies to

        govern the existing size of Company resulting in management identifying a control environment deficiency. These same factors affected the effectiveness of the information flow to the finance department resulting in management’s determination of an information and communication deficiency.

        Management has amended its disclosure in the amended annual report on Form 40F filed concurrently herewith to include the dates of corrective actions and future corrective actions, discussed when the Company took corrective action with respect to communicating employees’ duties over financial reporting and has disclosed the costs were immaterial to the Company.

        Changes in Internal Control Over Financial Reporting

        Staff Comment No. 3.

        You state that “[e]xcept for the changes discussed above, there have been no changes that occurred during the period covered by this report that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.” Revise to state clearly that there were changes in your internal control over financial reporting that occurred during this
        period that have materially affected, or are reasonably likely to materially affect, your internal control over financial reporting.

        Company Response:

        We have updated the information requested on the amended annual report on Form 40-F/A filed concurrently herewith.

        We affirm the aforementioned statements and responses.

        In addition, we acknowledge that:

                        •

                        the Company is responsible for the adequacy and accuracy of the disclosure in its filings, including its annual report on Form 40-F;

                        •

                        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.

        If you should have any questions regarding the annual report or our response letter, please do not hesitate to contact me at 604-685-9775.

        Sincerely,

        Endeavour Silver Corporation

        “Dan Dickson”

        Dan Dickson

        Chief Financial Officer (Interim)

CORRESP
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        October 9, 2008

                        Via: EDGAR

                        Securities and Exchange Commission

                        Division of Corporate Finance

                        Mail Stop 7010

                        100 F Street, NE

                        Washington, D.C. 20549

                        Attention: Mr. John Lucas

                        Re:

                        Telephone conversation regarding

        Endeavour Silver Corp.

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

        Filed April 7, 2008

        File No. 001-33153

        Ladies and Gentlemen:

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

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

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

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

        Sincerely,

        /s/ Jason K. Brenkert

        Jason K. Brenkert

        DORSEY & WHITNEY LLP

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
       DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
September 23, 2008

Bradford Cooke Chairman and CEO Endeavour Silver Corp. #301-700 West Pender Street  Vancouver, British Columbia Canada, V6C 1G8
Re:  Endeavour Silver Corp.
Annual report for the fiscal year ended Dec. 31, 2007
Filed April 7, 2008
  File No. 1-33153

Dear Mr. Cooke:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise 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 deta iled as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.
Please understand that the purpose of our re view 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.

Form 40-F filed April 7, 2008

Cover Page

1. Please update the address of your agent for service of process in the United
States to include the agent’ s city, state, and zip code.

Bradford Cooke
Endeavour Silver Corp.
September 23, 2008 Page 2  Management’s Report on Internal Control Over Financial Reporting, page 5

2. Please revise to describe the events surrounding the determin ation that you did
not maintain effective internal control over financial report ing, including who
identified the weaknesses and when th e material weaknesses first began.
Include dates of corrective actions and a ny associated material costs.  Finally,
with respect to future actions that wi ll be taken to remediate the weakness,
disclose when they are to occur and any associated material costs.  Please be
sure to address when you intend to ta ke corrective action with respect to
communicating employees’ duties over financial reporting.

Changes in Internal Controls Over Financial Reporting, page 7

3. You state that “[e]xcept for the changes discussed above, there have been no
changes that occurred du ring the period covered by this report that have
materially affected, or are reasonably lik ely to materially affect, our internal
control over financial reporting.”  Revi se to state clearly that there were
changes in your internal control over fi nancial reporting that occurred during
this period that have materially affecte d, or are reasonably lik ely to materially
affect, your internal cont rol over financial reporting.

Closing Comments

As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent 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 co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Bradford Cooke
Endeavour Silver Corp. September 23, 2008 Page 3
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 comment s do not
foreclose the Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     Please contact John Lucas at (202) 55 1-5798 or me at (202) 551-3611 with any
questions.
Sincerely,

Anne Nguyen Parker Branch Chief
 cc: J. Lucas  Kenneth G. Sam, Esquire (303) 629-3450