November 16, 2005


Mr. Donald R. Willoughby
Chief Financial Officer
Getty Copper Inc.
1000 Austin Avenue
Coquitlam, British Columbia V3K 3PI


	Re:	Getty Copper Inc.
		Form 20-F for the Fiscal Year Ended December 31, 2004
Filed August 23, 2005
		Response letter dated October 13, 2005
      File No. 000-29578

Dear Mr. Willoughby:

      We have reviewed your response letter and filings and have
the
following comments.  We have limited our review to those issues we
have addressed in our 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.

General

1. You did not electronically file your response letter dated
October
13, 2005 as required by Subparts 232.100 and 232.101 of Regulation
S-
T.  Please electronically file your response letter, as well as
all
future correspondence.

2. In your next response, please provide the representations
regarding the adequacy and accuracy of your disclosures requested
at
the end of this letter.






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

Audit Report

3. We note your response to prior comment 3 from our letter dated
September 26, 2005 regarding the prior auditors reports.  Revise
the
explanatory heading to state from management`s perspective that:

* the audit report is a copy of the original report,
* the audit report has not been reissued by the auditing firm, and
* that you have been advised that the auditing firm has not
registered with the PCAOB as it has ceased to provide auditing
services to public companies for purposes of meeting their
reporting
obligations in the United States.


Engineering Comments

Exploration, page 19 and Non-Reseves (Resources), page 20

4. For Canadian companies, reserve and resource estimates must
conform to National Instrument 43-101 to be granted the exception
under Industry Guide 7, Instruction 3 to Paragraph (b)(5),
otherwise
all reserve and resource disclosures must conform to Industry
Guide
7.  Revise these sections, stating reserves and resources using
the
proper terminology or remove all reserves and resource estimates
from
the filing.

5. All mineral resource estimates must have "reasonable prospects
for
economic extraction."  This means that any reportable resource
estimates must have been delimited using an economically based
cutoff
grade to segregate resources from just mineralization.

* Disclose the cutoff grade used to delimit the tonnage estimates.
* Disclose the analysis and relevant factors that substantiate the
cutoff grades used were based on reasonable economic assumptions.
* The relevant factors must realistically reflect the following:
o Mine location and Deposit Scale
o Continuity of Mineralization
o Mining Method
o Metallurgical Processes
o Operational Costs (Mining & Processing)
o Capital Costs
o Reasonable metal prices based on the recent historic three-year
average.

If the resource estimates are not based on economic cutoffs,
remove
all reserve and resource estimates.


Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  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
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 Mark A. Wojciechowski at (202) 551-3759 or,
in
his absence, Karl Hiller at (202) 551-3686 if you have questions
regarding comments on the financial statements and related
matters.
You may contact George K. Schuler, Mining Engineer, at (202) 551-
3718
if you have questions related to engineering issues and related
disclosures.  Please contact me at (202) 551-3740 with any other
questions.


								Sincerely,



								H. Roger Schwall
								Assistant Director



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Mr. Donald R. Willoughby
Getty Copper Inc.
November 16, 2005
Page 1




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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010