UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

      August 26, 2005

Mr. Thomas A. Loucks
Trend Mining Company
President and Chief Executive Officer
5439 South Prince Street
Littleton, Colorado 80120


      Re:	Trend Mining Company
		Registration Statement on Form SB-2
      Filed April 18, 2005 and amended August 8, 2005
		File No. 333-124144

Dear Mr. Loucks:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise 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 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 review 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 on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.
Business and Properties

Properties, Page 18
1. We note your table of properties includes a column for the cost
of
properties, with a footnote explanation that this does not
represent
cost as defined by SEC guidelines.    Please remove this column
from
your property table and the related footnote disclosure to avoid
investor confusion.  Expand your description of the properties to
include all the information required by Securities Act Industry
Guide
7(b).

Risk Factors, page 3
2. We note your response number 10 and the disclosure you have
added
on page 7.  The fact that Mr. Kaplan and his affiliates can demand
repayment due to the completion of the private placement - whether
they choose to do so or not - appears to be a separate matter from
your ability to raise funds.  Break out this disclosure into a
separate risk factor addressing the impact on the company if Mr.
Kaplan chooses to exercise his right or repayment.  Also expand
the
disclosure on page 13 to specify that the recent private placement
satisfies the repayment condition.

Executive Compensation, page 29

Summary of Cash and Certain Other Compensation
3. We note your response to prior comment number 21.  However, Mr.
Ryan did serve as your chief executive officer during the last
fiscal
year ended September 30, 2004.  Item 402(a)(2) requires the
disclosure
of compensation awarded to "all individuals serving as the
registrant`s chief executive officer or acting in a similar
capacity
during the last completed fiscal year, regardless of
compensation." We
therefore reiterate that comment.

Related Party Transactions, page 36
4. We note your response number 26.  Provide that information in
the
registration statement.

Financial Statements

General

5. To the extent our comments on your annual financial statements
included in this Form SB-2 Amendment No. 1 result in revisions to
these statements, you should also file an amended Form 10-KSB and
10-Q
for the quarters ended December 31, 2004 and March 31, 2005 as
appropriate to reflect corresponding changes.  These amended
filings
should also reflect the error correction you have reported for the
year ended September 30, 2004.

Unaudited Financial Statements for the three months and six months
ended March 31, 2005

General

6. Update your unaudited financial statements to include interim
financial statements as of June 30, 2005, as required by Rule 3-
10(g)
of Regulation SB as part of your amended SB-2 filing in response
to
these comments.

Audited Financial Statements for the fiscal year ended September
30,
2004

Notes to Financial Statements

Note 4 - Capital Stock, page F-36

7. We have considered your response to our prior comment 40.  With
respect to the 8,868,174 warrants outstanding as of September 30,
2004, revise footnote four to include a table that summarizes the
number of warrants outstanding for each exercise price and
expiration
date as required under FAS 129, paragraphs 4.

Note 5 - Common Stock Options and Warrants, page F-38

8. We note that you have restated your financial statements for
the
accounting for the gain on sale of internal securities.  In the
fifth
paragraph, please remove the statement "this gain is reflected in
the
income statement as internal gain from sale of securities."

Note 6 - Related Party Transactions, page F-39

9. We have considered your response to our prior comment number
42.
Please revise footnote six to disclose the nature of the
relationship
of each identified related party to the registrant as required by
FAS
57, paragraphs 2-3.

Closing Comments

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment 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 cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
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 information required under the Securities Act of 1933
and
that they have provided all information investors require for an
informed investment decision.  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.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

?	should the Commission or the staff, acting pursuant to
delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

?	the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division
of Corporation Finance in connection with our review of your
filing or
in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering of
the securities specified in the above registration statement.  We
will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Gary Newberry at (202) 824-5567 or Jill
Davis,
Accounting Branch Chief, at (202) 942-1996, if you have questions
regarding comments on the financial statements and related
matters.
Please contact Carmen Moncada-Terry at (202) 942-1908 or, in her
absence, the undersigned, at (202) 942-1870.  Direct all
correspondence to the following ZIP code: 20549-0405.


      					Sincerely,



      					H. Roger Schwall
      Assistant Director


cc: 	H. Rothman
      C. Moncada-Terry

Mr. Thomas A. Loucks
Trend Mining Company
August 26, 2005
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