Stillwater Mining Company
1321 Discovery Drive
Billings, Montana 59102
March 11, 2013
VIA EDGAR TRANSMISSION
David L. Orlic, Esq.
Special Counsel
Office of Mergers and Acquisitions
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-3628
| Re: | Stillwater Mining Company |
| Preliminary Proxy Statement |
| Filed March 1, 2013 by Stillwater Mining Company |
| File No. 001-13053 |
Dear Mr. Orlic:
In response to your request in the letter dated March 8, 2013 relating to the above-referenced filing on Schedule 14A, Stillwater Mining Company (“Stillwater”) hereby acknowledge the following:
| 1. | Stillwater is responsible for the adequacy and accuracy of the disclosure in the filing; |
| 2. | Comments from the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| 3. | Stillwater 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 |
***
David L. Orlic, Esq.
March 11, 2013
Page 2
| Very truly yours, | ||||||
| STILLWATER MINING COMPANY | ||||||
| By: | /s/ Brent R. Wadman | |||||
| Name: | Brent R. Wadman, Esq. | |||||
| Title: | Corporate Secretary and | |||||
| Deputy General Counsel | ||||||
| cc: | Richard J. Grossman, Esq., Skadden, Arps, Slate, Meagher & Flom LLP |