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

         DIVISION OF
CORPORATION FINANCE
Mail Stop 7010

      September 30, 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 September 15, 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.
Risk Factors, page 3

1. We note your response to comment number 2 and the amended
disclosure.  As previously noted, each risk must be stated plainly
and
directly.  Revise this risk factor to remove the mitigating
language
that you have included, namely "[h]owever, the company believes
that
Mr. Kaplan and his affiliates in the Kaplan Group will not
exercise
such right."

 Financial Statements for the Period Ended June 30, 2005

Note 3 - Summary of Significant Accounting Policies, page F-12

Going Concern

1.	Please reconcile the amount disclosed as your accumulated
deficit
as of June 30, 2005 to your statements of stockholders equity.

Note 9 - Convertible Bridge Loans, page F-15

2.	Please expand your disclosure to address the modification in
the
event of your completion of a private placement, as disclosed on
page
8 and 12.

Note 11 - Subsequent Event, page F-17

3.	Please expand your disclosure to address the terms of the
advances from your officers and directors which you disclose on
page
36.

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

Notes to Financial Statements

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

4.	Your response to comment eight in our letter of August 26,
2005
indicated you had complied with the comment.  We are unable to
locate
the revisions to the disclosure.   Therefore, we reissue our prior
comment number eight, as follows:
We note that you have restated your financial statements for the
accounting for the gain on sale of internal securities.  In the
fourth
paragraph on page F-38, remove the statement "this gain is
reflected
in the income statement as internal gain from sale of securities."



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) 551-3761 or Jill
Davis,
Accounting Branch Chief, at (202) 551-3683, if you have questions
regarding comments on the financial statements and related
matters.
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: 	H. Rothman
      C. Moncada-Terry