United States securities and exchange commission logo





                  August 6, 2020

       Karl L. Hanneman
       Chief Executive Officer
       International Tower Hill Mines Ltd.
       2300-1177 West Hastings Street
       Vancouver, British Columbia, Canada V6E 2K3

                                                        Re: International Tower
Hill Mines Ltd.
                                                            Registration
Statement on Form S-3
                                                            Filed July 31, 2020
                                                            File No. 333-240276

       Dear Mr. Hanneman :

              This is to advise you that we have not reviewed and will not
review your registration
       statement.

               Please refer to Rules 460 and 461 regarding requests for
acceleration. We remind you
       that the company and its management are responsible for the accuracy and
adequacy of their
       disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

              Please contact Anuja A. Majmudar, Attorney-Advisor, at
202-551-3844 with any
       questions.




                  Sincerely,


                  Division of Corporation Finance

                  Office of Energy & Transportation
       cc:                                              David Crandall