[GOLDEN MINERALS COMPANY LETTERHEAD]
April 21, 2011
Via EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549
Attention: Roger H. Schwall
Re: Golden Minerals Company
Registration Statement on Form S-3 (File No. 333-172363)
Filed February 18, 2011, amended on April 4, 2011
Dear Mr. Schwall:
Pursuant to Rule 461 of the Securities Act of 1933, as amended, Golden Minerals Company (the “Company”) hereby requests acceleration of the effective date of the above-referenced Registration Statement so that it may become effective at 4:00 p.m. Eastern Daylight Time on Tuesday, April 26, 2011, or as soon thereafter as practicable.
The Company acknowledges that:
· should the Commission or 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 disclosures in the Registration Statement; 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 advise Brian Boonstra of Davis Graham & Stubbs LLP at (303) 892-7348 when the order declaring the Registration Statement effective is signed.
| Sincerely, |
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| /s/ ROBERT P. VOGELS |
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| ROBERT P. VOGELS |
| Senior Vice President and Chief Financial Officer |
cc: Parker Morrill
Deborah Friedman
Brian Boonstra