November 16, 2009
Via EDGAR and Federal Express
Securities and Exchange Commission
Division of Corporate Finance
100 F St., N.E.
Washington, D.C. 20549-4628
Attention: H. Roger Schwall
Re: Golden Minerals Company
Registration Statement on Form S-1
Filed October 14, 2009
File No. 333-162486
Dear Mr. Schwall:
On behalf of Golden Minerals Company (the “Company”), set forth below is the Company’s response to the comments of the Staff of the Division of Corporation Finance, which were delivered in your letter dated November 4, 2009, regarding the Company’s Registration Statement on Form S-1 as filed on October 14, 2009. In connection herewith, the Company has filed by EDGAR Amendment No. 1 to the Registration Statement on Form S-1. Enclosed is a copy of Amendment No. 1 to the Registration Statement marked to reflect the changes made. If additional copies are needed, please let us know.
The Staff’s November 4 letter notes that disclosure in the Registration Statement must be updated and all omitted exhibits must be filed prior to effectiveness. The Company has revised the Registration Statement to update various disclosure items and has filed several of the exhibits omitted from the initial filing. In the next several weeks, the Company intends to file a further amendment to the Registration Statement which will include all omitted exhibits. In addition, the Company confirms that the subsequent amendment will include all remaining disclosure items (including the identification of the selling stockholders) and will update disclosure throughout the prospectus as necessary.
Brian Boonstra • 303 892 7348 • brian.boonstra@dgslaw.com
1550 Seventeenth Street · Suite 500 · Denver, Colorado 80202 · 303 892 9400 · fax 303 893 1379
www.dgslaw.com
Should you require further clarification of any of the issues raised in this letter, please contact the undersigned at (303) 892-7348.
| Sincerely, | |
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| /s/ Brian Boonstra | |
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| Brian Boonstra | |
| for | |
| DAVIS GRAHAM & STUBBS LLP | |
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cc: | Joseph Sun |
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| Timothy Levenberg |
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| Robert P. Vogels |
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