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                                                     September 22, 2005

BY EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.  20549

Attention:    Jill S. Davis
              Branch Chief

Re:      Barrick Gold Corporation
         Form 40-F for Fiscal Year Ended December 31, 2004
         Filed March 31, 2005
         File No. 001-09059

Dear Ms. Davis:

                  We hereby acknowledge receipt of the comment letter dated
August 22, 2005 (the "Comment Letter") from the staff (the "Staff") of the
Securities and Exchange Commission (the "Commission") concerning the above
captioned Annual Report on Form 40-F for the fiscal year ended December 31,
2004 (the "40-F").

                  We submit this letter in response to the Comment Letter.  For
ease of reference, we have reproduced the text of the comments in bold-face type
below, followed by our responses.  Terms used but not defined herein have the
meanings set forth in the 40-F.





                           --------------------------


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                           RESPONSES TO STAFF COMMENTS


Form 40-F for the Fiscal Year Ended December 31, 2004
-----------------------------------------------------

Narrative Description of the Business, page 15
----------------------------------------------

Principal Regions, page 23
--------------------------

1.       We note that your presentation of "Total cash costs - per US GAAP,"
         under this heading and throughout your filing, equals "cost of sales
         and other operating expenses less accretion expense and reclamation
         costs at non-operating mines." Please note that your cost of sales line
         item, which excludes amortization of property, plant and equipment,
         does not follow the full absorption costing principle since the measure
         does not include all costs and expenses associated directly with or
         allocated to your products sold. We believe cost of sales should
         include inventoriable costs of assets incident to or necessary for
         production or manufacturing, including applicable depreciation,
         depletion and amortization. Please revise your presentation accordingly
         or explain to us why it is appropriate to disclose this measure in your
         filing. If you determine it is appropriate to disclose this measure,
         please revise your caption to refer to this measure in a manner that
         more clearly explains how it is calculated and include all disclosures
         required by Question 8 of the Division of Corporation Finance's June
         13, 2003 Frequently Asked Questions Regarding the Use of Non-GAAP
         Financial Measures, located at:
         http://www.sec.gov/divisions/corpfin/faqs/nongaapfaq/htm. We note a
         similar measure disclosed on page 93 entitled "Total cash production
         costs - per US GAAP."

         Response: Consistent with the income statement presentation adopted by
         a number of SEC registrants, Barrick presents amortization on a
         separate line on its income statement, distinct from cost of sales. As
         required by SAB Topic 11B, Barrick includes a reference on its income
         statement to the fact that cost of sales excludes amortization, and a
         cross-reference to note 5 to the financial statements, where Barrick
         discloses the amount of amortization that is excluded from cost of
         sales.

         Barrick includes a performance measure in its Management's Discussion
         and Analysis referred to as "total cash costs per ounce". In preparing
         its 2004 Annual Information Form, Barrick concluded that this statistic
         is a non-GAAP performance measure because certain elements of "cost of
         sales" on its income statement were excluded from the calculation of
         the measure. Barrick therefore included disclosure on pages 91 through
         94 of its Annual Information Form filed as Exhibit 1 to the Form 40-F
         to explain the reasons why it presents this performance measure, the
         method of calculation and a reconciliation to what it believed to be
         the most directly comparable GAAP financial measure.

         Total cash costs per ounce statistics are a key performance measure
         that management uses to monitor performance. Barrick uses these
         statistics internally to assess how well its producing mines are
         performing compared to internal plans, and also to assess the overall



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         effectiveness and efficiency of its mining operations. Barrick
         understands that certain investors also use these statistics to assess
         its performance.

         Barrick believes that the inclusion of these statistics, together with
         commentary explaining trends and changes in the statistics, enhances
         the ability of investors to assess its performance. The inclusion of
         total cash costs per ounce statistics enables investors to better
         understand year on year changes in cash production costs, which in turn
         affect Barrick's profitability and ability to generate cash flow.

         Other senior gold producers prepare and publish equivalent statistics,
         which certain investors use to gauge the relative performance of
         Barrick to other companies in the gold mining industry.

         In response to the comments made by the Staff of the SEC, Barrick
         intends to revise the caption to refer to the measure in a manner that
         more clearly explains how it is calculated and to augment the
         disclosure relating to this performance measure in its future filings,
         taking into consideration the disclosures required by Question 8 of the
         Division of Corporation Finance's June 13, 2003 Frequently Asked
         Questions Regarding the Use of Non-GAAP Financial Measures. Barrick
         plans to add disclosure to more clearly communicate to investors that
         total cash costs per ounce excludes amortization, including the effect
         of the exclusion of amortization on this statistic.

Note 16.  Financial Instruments, page 97
----------------------------------------

Accounting policy for derivatives, page 100
-------------------------------------------

2.       We note that you have elected to designate your gold and silver sales
         contracts as "normal sales contracts" under paragraph 10(b) of FAS 133.
         We further note under your disclosure of off balance sheet arrangement
         on page 53 in your MD&A that you have had gold sales contracts in the
         past with bullion-banking counterparties. With respect to your gold and
         silver sales, please provide an analysis of the different type of
         contracts that you presently have, indicating the (i) counterparties
         involved and (ii) the type of product that you physically deliver from
         your mines to each of the counterparties involved. Please specify
         whether or not the counterparty that receives physical delivery of an
         unrefined product from your mine is the same counterparty that receives
         physical delivery of a refined product from your mine.

         Response:  Barrick currently has the following three types of gold and
         silver sales contracts:

i)       Gold and Silver Bullion Sales Contracts

         An unrefined product (gold dore) is produced at Barrick's mines and
         sent to metal refineries, who are not counterparties to the gold and
         silver bullion sales contracts, where it is refined into a refined
         product (gold and silver bullion). The refinery acts as an agent for
         Barrick and does not take title to the gold dore. Ownership of the


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         unrefined product (dore) remains with Barrick during the refining
         process. Upon completion of the refining process, a refined product
         (gold and silver bullion) is physically delivered to the counterparties
         to the gold and silver bullion sales contracts, whereon ownership is
         transferred from Barrick to the counterparties. Under these sales
         contracts a refined product is delivered to the counterparties, and
         Barrick does not deliver an unrefined product to those counterparties.

         The key terms of these contracts are described on pages 53 through 57
         of Barrick's MD&A filed as Exhibit 3 to the Form 40-F. The
         counterparties involved with this type of contract are:

         AIG International Inc.
         Barclays Bank PLC
         Bank of Nova Scotia
         Canadian Imperial Bank of Commerce
         Citibank NA
         Commerzbank International SA
         Deutsche Bank AG
         Dresdner Bank AG
         HSBC Bank USA
         J. Aron & Company
         JP Morgan Chase Bank
         Macquarie Bank Limited
         Mitsui & Co. Precious Metals Inc.
         Morgan Stanley Capital Group Inc.
         Royal Bank of Canada
         Societe Generale
         UBS AG

         As disclosed in the Form 40-F, Barrick elected to designate these
         contracts as normal sales contracts under paragraph 10(b) of FAS 133.
         Under these gold and silver bullion sales contracts, Barrick physically
         delivers gold and silver bullion to the counterparties.

ii)      Ore Sales Contracts

         At the Eskay Creek mine, Barrick produces and sells ore to various
         customers under ore sales contracts.

         The counterparties involved with this type of contract are:

         Dowa Mining Co. Ltd.
         Noranda Inc.

         Under these contracts, an unrefined produce (ore) is physically
         delivered to the counterparties and sold at a price established under
         the terms of the contracts.


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iii)     Concentrate Sales Contracts

         At the Eskay Creek and Bulyanhulu mines, Barrick produces gold in a
         concentrate form that is sold to various smelters under concentrate
         sales contracts.

         The counterparties involved with this type of contract are:

         Dowa Mining Co. Ltd
         Noranda Inc.
         Mark Rich & Co. Investment AG
         Pan Pacific Copper Co. Ltd.
         Sumitomo Metal Mining Co. Ltd.
         Teck Cominco Metals

         Under these concentrate sales contracts Barrick physically delivers an
         unrefined product (concentrate) to the counterparties, which is sold at
         a price established under the terms of the contracts.

Closing Comments
----------------

                  In connection with responding to our comments, please provide,
in writing, a statement from the company acknowledging that:

                  o        the company is responsible for the adequacy and
                           accuracy of the disclosure in the filing;

                  o        staff comments or changes to disclosure in response
                           to staff comments do not foreclose the Commission
                           from taking any action with respect to the filing;
                           and

                  o        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.

         Response:   Attached as Appendix A to this letter is the requested
                     statement.

                                      *****

                  We appreciate your assistance in reviewing this response
letter.  Please direct all questions or comments regarding this filing to the
undersigned at 416-307-7436.

                                           Sincerely,

                                           /s/ Richard D. Ball

                                           Richard D. Ball
                                           Vice President
                                           Financial Reporting & Risk Analysis


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         Attachment

         cc:      Jennifer Goeken, Securities and Exchange Commission
                  Audit Committee of Barrick Gold Corporation
                  Jamie C. Sokalsky, Executive Vice President & Chief Financial
                  Officer, Barrick Gold Corporation
                  Jerry Whelan, PricewaterhouseCoopers LLP
                  Jennifer Mazin, Shearman & Sterling LLP


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                                                                     APPENDIX A

                                                September 22, 2005



BY EDGAR

Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010

                            Barrick Gold Corporation
                 Annual Report on Form 40-F (File No. 001-09059)
                 -----------------------------------------------

          Reference is made to the Annual Report on Form 40-F for the fiscal
year ended December 31, 2004 (File No. 001-09059) (the "Annual Report") filed by
Barrick Gold Corporation (the "Company") on March 31, 2005 with the Securities
and Exchange Commission (the "Commission"). The Company acknowledges that the
Company is responsible for the adequacy and accuracy of the disclosure in the
Annual Report. The Company further acknowledges that comments of the staff of
the Commission or changes to disclosure in response to such comments do not
foreclose the Commission from taking any action with respect to the Annual
Report. In addition, the Company further acknowledges that it may not assert the
comments of the staff of the Commission as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.


                                             Very truly yours,

                                             Barrick Gold Corporation


                                             By:  /s/ Richard D. Ball
                                                ---------------------
                                                Name:  Richard D. Ball
                                                Title: Vice President
                                                       Financial Reporting
                                                       and Risk Analysis


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