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

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

      September 30, 2005

Mr. James E. McKay
Chief Executive Officer
Battle Mountain Gold Exploration Corp.
One East Liberty Street
Sixth Floor, Suite 9
Reno, Nevada 89504

      Re:	Battle Mountain Gold Exploration Corp.
		Schedule 14C
      Filed June 17, 2005
		File No. 0-50399
		Form 10-QSB for the period ended June 30, 2005
		Filed July 20, 2005
		File No. 0-50399

Dear Mr. Mc. Kay:


      We have limited our review of your filing 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.

	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.
General

1. Please provide us with marked copies clearly reflecting the
changes
you have made in response to the comments.  This will speed up the
time we need to review your materials.

Notice of Annual Meeting

2. Demonstrate for us that verbal consents are sufficient for
approving proposals under state law so that you do not need to
solicit
proxies or written consents from shareholders.

Certain Relationships and Related Transactions

3. We note your revised disclosure.  Indicate how the re-pricing
"more
accurately and consistently reflect[ed] actual market price."
Indicate the market price at the time of the original agreement
and at
the time of the re-pricing.  You also indicate that the re-pricing
was
done to "maintain investor interest."  Clarify whether the
investors
were bound by the original agreement and, if so, what you mean by
that
statement.

Form 10-QBS for the period ended June 30, 2005

Controls and Procedures

4. Revise your disclosure to provide information comparable to
that
requested in comments 7, 8 and 9 for your Form 10-KSB in our
letter
dated July 12, 2005.

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 reviewed by the staff 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.

      If you have any questions, please contact Carmen Moncada-
Terry
at (202) 551-3687 or, in her absence, the undersigned at (202)
551-
3740.



      Sincerely,



      H. Roger Schwall
      Assistant Director


cc:	M. Morrison
      C. Moncada-Terry



Mr. James E. McKay
Battle Mountain Gold Exploration Corp.
September 30, 2005
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