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                            November 3, 2020

       Christopher Richards
       Chief Financial Officer
       SILVER BULL RESOURCES, INC.
       777 Dunsmuir Street
       Suite 1610
       Vancouver, British Columbia V7Y 1K4

                                                        Re: SILVER BULL
RESOURCES, INC.
                                                            Preliminary Proxy
Statement on Schedule 14A
                                                            Filed October 23,
2020
                                                            File No. 001-33125

       Dear Mr. Richards:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Preliminary Proxy Statement Filed October 23, 2020

       About the Special Meeting
       Why is the Company seeking approval to increase the number of authorized
shares of Silver Bull
       common stock?, page 5

   1.                                                   We note that the
proposed increase in the number of authorized shares is materially
                                                        related to an option
agreement dated as of August 12, 2020 and would enable the
                                                        Company to issue shares
pursuant to such agreement, disclosed in a Form 8-K filed on
                                                        August 18, 2020.
However, it does not appear that you have included the option
                                                        agreement as an exhibit
nor filed the option agreement as an exhibit to the Form 8-K in
                                                        accordance with Item
1.01 of Form 8-K. Please amend your proxy statement to include
                                                        the option agreement as
an exhibit.
 Christopher Richards
SILVER BULL RESOURCES, INC.
November 3, 2020
Page 2

        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-Adviser, at (202) 551-3844
or, in her
absence, Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any
other questions.



                                                          Sincerely,
FirstName LastNameChristopher Richards
                                                          Division of
Corporation Finance
Comapany NameSILVER BULL RESOURCES, INC.
                                                          Office of Energy &
Transportation
November 3, 2020 Page 2
cc:       Brian Boonstra
FirstName LastName