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                                           October 2, 2006


Ms. Lily Dang
United States Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549-7010

                               Ivanhoe Mines Ltd.
                               ------------------

Dear Ms. Dang:

         Further to our  telephone  message,  the  purpose of this letter is to
confirm the receipt by Ivanhoe Mines Ltd.  (the  "Company") of the letter dated
September 28, 2006 from Karl Hiller,  Branch Chief (the "Comment Letter"),  and
the Company's intention to file its response. As we mentioned, the Company will
schedule a meeting of its Audit  Committee  later this  month.  In light of the
Company's corporate governance  practices,  it intends to provide the Company's
Audit Committee with a report and the opportunity to discuss the Comment Letter
and the Company's  response prior to filing the response.  Accordingly,  and as
orally approved by you, the Company intends to file its response to the Comment
Letter following such meeting not later than October 31, 2006.


         If you have any  questions  or  comments,  please do not  hesitate  to
contact me.

                                               Very truly yours,

                                               /s/ Andrew J. Foley
                                               --------------------------
                                               Andrew J. Foley

cc:   Tony Giardini (Ivanhoe Mines Ltd.)
      Beverly Bartlett (Ivanhoe Mines Ltd.)