July 25, 2005



Mr. R. Herbert Hampton
Chief Executive Officer
Golden Cycle Gold Corporation
Suite 201
1515 South Tejon
Colorado Springs, CO  80906


	Re:	Golden Cycle Gold Corporation
		Form 10-K for Fiscal Year Ended December 31, 2004
Filed March 31, 2005
		Form 10-Q for Fiscal Quarter Ended March 31, 2005
      Filed May 13, 2005
		Response letter dated July 6, 2005
      File No. 1-09385


Dear Mr. Hampton:

We have reviewed your response letter and have the following
comments.  We have limited our review of your filing to those
issues
we have addressed in our comments.  Please provide a written
response
to our comments.  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-K for the Fiscal Year Ended December 31, 2004

Item 8 - Financial Statements and Supplementary Data

Consolidated Balance Sheets, page 28

1. We note your explanation that the Company`s short term
investments
in certificates of deposit are used to keep cash accessible for
the
Company`s operations and your representation that the Company`s
primary activities in 2005 will include managing the joint venture
interests, continuing the regional study in southwest Colorado,
and
beginning the drilling and testing phase of the Illipah gold
prospect
in Nevada (for which the Company has budgeted $259,000).  Please
further explain why the Company requires substantial liquid assets
for its operations.  In so doing, please include a 2005 estimate
of
the operational costs of the Company, along with the operational
costs associated with each of the aforementioned projects.

2. Please further explain the capacity in which the Company acts
with
respect to its participation in the Cripple Creek & Victor Gold
Mining Company, the joint venture with AngloGold Ashanti
(Colorado)
Corp.  Specifically, please explain what activities the Company
engages in with respect to the joint venture and what percentage
of
the joint venture`s interest the company holds.

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.

	You may contact Gary Newberry at (202) 551-3761, or Kim
Calder,
Assistant Chief Accountant, at (202)-551-3701 if you have
questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3684 with any other questions.

								Sincerely,



								April Sifford
								Branch Chief



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Mr. R. Herbert Hampton.
Golden Cycle Gold Corporation
July 25, 2005
page 1




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