October 7, 2005 Mr. David A. Adamson President and Chief Executive Officer Rubicon Minerals Corporation 1540-800 West Pender Street Vancouver, British Columbia V6C 2V6 Canada 	Re:	Rubicon Minerals Corporation 		Form 20-F for the Year Ended December 31, 2004 Filed March 15, 2005 		File No. 001-31345 		Supplemental Response Dated September 28, 2005 Dear Mr. Adamson: We have reviewed your filings and have the following comment. We have limited our review of your filings to those issues we have addressed in our comments. Please provide a written response to our comment. Please be as detailed as necessary in your explanation. After reviewing this information, we may raise additional comments. The page number referenced below correspond to those utilized in the Form 20-F. Form 20-F for the Year Ended December 31, 2004 Consolidated Financial Statements, page 65 Differences between Canadian and United States Generally Accepted Accounting Principles, page 86 1. We note your response to our prior comment number one in our letter dated September 9, 2005. We understand you considered CICA Emerging Issues Committee Abstract #126 and FASB Statement No. 144 for Canadian and U.S. GAAP reporting purposes, respectively. It is unclear to us how you were able to conclude that the estimated future cash flows are insufficient to recover carrying amounts of the property for reporting under U.S. GAAP if you do not have a basis for preparing a projection of the estimated future net cash flow from the property, which is one of the factors mentioned in the Abstract #126. Please elaborate on how you applied FASB Statement No. 144 and the Abstract #126. Closing Comments Please respond to this comment within 10 business days or tell us when you will provide us with a response. Please understand that we may have additional comments after reviewing your response to our comment. You may contact Yong Choi at (202) 551-3758 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 ?? ?? ?? ?? Mr. Adamson Rubicon Minerals Corporation October 7, 2005 Page 1 UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE MAIL STOP 7010