September 15, 2005



Mr. Michael L. Carroll
Chief Financial Officer
Cumberland Resources Ltd.
950-505 Burrard Street
Vancouver, B.C.  V7X 1M4 Canada


	Re:	Cumberland Resources Ltd.
		Form 20-F for Fiscal Year Ended December 31, 2004
Filed June 30, 2005
		File No. 1-31969


Dear Mr. Carroll:

      We have reviewed your filing 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.

	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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 20-F for the Fiscal Year Ended December 31, 2004

Engineering Comments

General

1. Insert a small-scale map showing the location and access to the
property.  Note that SEC`s EDGAR program now accepts digital maps,
so
please include these maps in any future amendments that are
uploaded
to EDGAR.  It is relatively easy to include automatic links at the
appropriate locations within the document to GIF or JPEG files,
which
will allow the figures and/or diagrams to appear in the right
location when the document is viewed on the Internet.  For more
information, please consult the EDGAR manual, and if addition
assistance is required, please call Filer Support at 202-942-8900.
Otherwise, provide the map to the staff for review.

General Development of the Business of the Company, Page 13

2. Please correct the weighted average grade for the measured and
indicated resource estimate found in the fifth paragraph.

3. The cutoff grade is a critical component used to evaluate the
potential of the mineral properties. Disclose the operating costs
and
recovery parameters used to determine the cutoff grade estimate.
Show that this calculation demonstrates the cutoff grade or tenor
used to define a mineral resource has reasonable prospects for
economic extraction.  In establishing the cut-off grade, it must
realistically reflect the location, deposit scale, continuity,
assumed mining method, metallurgical processes, costs, and
reasonable
metal prices.

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.

	 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
Exchange Act of 1934 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company 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.

      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 our review of your filing or in
response to our comments on your filing.

      You may contact George K. Schuler, Mining Engineer, at (202)
551-3718 with questions about engineering comments.  Please
contact
me at (202) 551-3740 with any other questions.

							Sincerely,



							H. Roger Schwall
							Assistant Director


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Mr. Michael L. Carroll
Cumberland Resources Ltd.
September 15, 2005
page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010