Dunn Mining Inc.

     9867 Okanagan Centre Road * Lake Country, BC V4V 2J3  * Tel 555-555-5555
       				Fax 555-555-1515


June 20, 2007




U.S. Securities & Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C. 20549
Mail Stop 7010

ATTENTION:  JASON WYNN

Dear Sirs:

RE:    DUNN MINING INC.  - FORM SB-2, (FILE NO. 33-141505)

We  are  in  receipt  of  your comment letter dated April 3, 2007 concerning our
registration statement on Form 20-F filed December 21, 2006.  We respond to your
comments as follows and provide  an  amended  registration  statement  for  your
review:

Registration Statement on Form SB-2

Determination of Offering Price, page 8

   1.  PROVIDE  FURTHER  DETAILS  REGARDING  THE FACTORS THAT WERE CONSIDERED IN
       DETERMINING  THE  OFFERING  PRICE.  WE  NOTE  YOUR  DISCLOSURE  THAT  THE
       OFFERING  PRICE  WAS  DETERMINED BASED UPON THE PRICE OF THE LAST SALE OF
       YOU  COMMON  STOCK  TO  INVESTORS.  HOWEVER,  WE  ALSO  NOTE OF YOUR SOLE
       OFFICE AND DIRECTOR, PURCHASED  THEIR  SHARES  IN A PRIVATE PLACEMENT FOR
       $0.01 PER SHARE.  SEE ITEM 505 OF REGULATION S-B.

       The price of the shares that  we  are offering was arbitrarily determined
       and bears no relationship whatsoever  to our assets, earnings, book value
       or other criteria of value. Among the factors considered were our lack of
       operating  history,  our  relative  cash requirements, and the fact that,








       during the process,  we  had completed the purchase of the Smoke property
       from Mr.Loney.

       We have amended the document accordingly.



Security Ownership of Certain Beneficial Owners and Management, page 15

   2.  PLEASE PROVIDE ALL OF THE DISCLOSURE REQUIRED  BY  ITEM 403 OF REGULATION
       S-B.   FOR  INSTANCE, PLEASE  CLARIFY  WHETHER MR. GREGORY  BYRNE  SHARES
       BENEFICIAL  OWNERSHIP  WITH  ANYONE  ELSE.  FOR  INSTANCE,  WE  NOTE THAT
       SEVERAL OF THE SELLING  SHAREHOLDERS  SHARE  THE  SAME  LAST NAME AS  MR.
       BYRNE.  SEE  INSTRUCTIONS  TO  ITEM 403 OF REGULATION S-B.

       Please be advised that Mr. Bryne does not share beneficial ownership with
       anyone else. We have amended the document accordingly, and to provide all
       of the disclosure required by Item 403 of Regulation S-B.


Finally, please be advised that we have updated the financial information in the
SB-2  with  a  more  recent Financial Statement, and the necessary corresponding
changes in the body of the document.


Yours truly,

DUNN MINING INC.

PER: /S/ GREGORY PAUL BYRNE
     ----------------------
     GREGORY PAUL BYRNE