September 26, 2007

Via U.S. Mail and Facsimile

Colin K. Benner
Chief Executive Officer
Lundin Mining Corporation
Suite 2101
855 West Georgia Street
Vancouver, British Columbia
Canada V6C 3E8

RE:		Lundin Mining Corporation
		Form 40-F for the fiscal year ended December 31, 2006
		File No. 1-33086

Dear Mr. Benner:

      We have limited our review of your Form 40-F for the fiscal
year ended December 31, 2006, to disclosures relating to your
contacts with countries that have been identified as state
sponsors
of terrorism.  Our review with respect to this issue does not
preclude further review by the Assistant Director group with
respect
to other issues.  At this juncture, we are asking you to provide
us
with supplemental information, so that we may better understand
your
disclosure.  Please be as detailed as necessary in your response.
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
filings.
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.


General
1. We note that Exhibit 99.1 to your 40-F for the fiscal year
ended
December 31, 2006, states that through your subsidiaries you hold
interests in properties in a number of countries, including Iran.
We
note also that your website previously discussed your
participation
in the Lundin Group of Companies which you identified as including
Tanganyika Oil Company Ltd., a company you identified as having
operations in Syria.  Your website also described the Lundin Group
of
Companies as including Lundin Petroleum AB, a company reported to
conduct operations in Sudan.
In light of the fact that Iran, Sudan and Syria have been
identified
as state sponsors of terrorism by the U.S. State Department and
are
subject to U.S. economic sanctions and export controls, please
describe your current, past and anticipated contacts with these
countries, whether directly or through subsidiaries or affiliated
entities or other indirect arrangements.  Discuss the materiality
of
the contacts to you, and whether, individually or in the
aggregate,
they constitute a material investment risk to your security
holders.
2. Your materiality analysis should address materiality in
quantitative terms, including the approximate dollar amount of
revenues, assets and liabilities associated with Iran, Sudan and
Syria.  Please also address materiality in terms of qualitative
factors that a reasonable investor would deem important in making
an
investment decision, including the potential impact of corporate
activities upon a company`s reputation and share value.
In this regard, we note that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Pennsylvania legislature has adopted a resolution
directing its Legislative Budget and Finance Committee to report
annually to the General Assembly regarding state funds invested in
companies that have ties to certain terrorist-sponsoring
countries.
The Missouri Investment Trust has established an equity fund for
the
investment of certain state-held monies that screens out stocks of
companies that do business with U.S.-designated state sponsors of
terrorism.  A number of U.S. states have adopted or are
considering
legislation regarding the investment of certain state assets in,
and/or requiring the divestment of certain state assets from,
companies that do business with Sudan and/or Iran.  Finally,
Harvard
University, Yale University, Stanford University, and other
educational institutions have adopted policies prohibiting
investment
in, and/or requiring divestment from, companies that do business
with
Sudan.  Your materiality analysis should address the potential
impact
of the investor sentiment evidenced by such actions directed
toward
companies that have operations associated with Iran, Sudan and
Syria.
3. Advise us whether you have provided into Iran any products,
including component parts, or any services, that have military
uses;
and whether, to the best of your knowledge, understanding or
belief,
any such products and/or services have been put to military use by
the Iranian government and, if so, the uses to which they have
been
put.

Closing Comments

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please submit your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the 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 the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, 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 filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; 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 filings or in response
to
our comments on your filings.



      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Jack
Guggenheim
at (202) 551-3523 if you have any questions about the comment or
our
review.  You may also contact me at (202) 551-3470.


								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk



cc: 	Roger Schwall
		Division of Corporation Finance
Colin K. Benner
Lundin Mining Corporation
September 26, 2007
Page 1









UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE