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United States securities and exchange commission logo





                            November 14, 2022

       Daniel Dominguez
       Chief Financial Officer
       Buenaventura Mining Company Inc.
       Las Begonias 415 Floor 19
       San Isidro, Lima 27, Peru

                                                        Re: Buenaventura Mining
Company Inc.
                                                            Form 20-F for the
Fiscal Year ended December 31, 2021
                                                            Filed May 13, 2022
                                                            File No. 001-14370

       Dear Daniel Dominguez:

              We have reviewed your October 24, 2022 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       September 19, 2022 letter.

       Form 20-F for the Fiscal Year ended December 31, 2021

       Information on the Company, page 26

   1.                                                   We note your response
to prior comment 1 stating that you do not plan to provide any
                                                        information for the
Julcani and La Zanja properties in future filings because you do not
                                                        consider them to be
material and have not prepared estimates of mineralization consistent
                                                        with the definitions
and standards in Subpart 1300 of Regulation S-K.

                                                        However, even though
you may consider and identify the Julcani and La Zanja properties
                                                        as not material, you
would nevertheless need to provide the information prescribed for
                                                        summary disclosure
under Item 1303 of Regulation S-K. Further, while a technical report
                                                        summary is not required
for a non-material property, based on Item 1302(b) of Regulation
                                                        S-K, estimates of
resources and reserves must be prepared by a qualified person in
 Daniel Dominguez
Buenaventura Mining Company Inc.
November 14, 2022
Page 2
         accordance with Item 1302(e) of Regulation S-K. Please submit the
revisions that you
         propose in the form of a draft amendment to comply with the
aforementioned guidance.
2.       We note that in response to prior comment two you propose to include a
map that appears
         to be an overview indicating the general location of all properties to
address Item
         1303(b)(1) of Regulation S-K. However, Item 1304(b)(1)(i) of
Regulation S-K requires
         disclosure of a property specific map for each material property. The
maps should be
         accurate to within one mile and based on an easily recognizable
coordinate system.

         We also note that you agreed to disclose the total cost and book value
of each property
         and its associated plant and equipment to comply with Item
1304(b)(2)(iii) of Regulation
         S-K. However, we do not see these details among your proposed
revisions.

         Please submit a complete draft amendment with all proposed changes
marked; and include
         a reference to the particular page and paragraph or section where
revisions appear in
         response to each comment. We reissue prior comment two.
3.       We note that the revisions you proposed in response to prior comment 3
continue to omit
         the point of reference in which mineral resources and reserves are
presented. For example,
         if mineral resources and reserves are presented as in-situ materials
(prior to mining losses
         and processing losses), as mill feed (after mining losses and prior to
processing losses), or
         on some other basis, this should be evident from your disclosures.
Please comply with
         Item 1304(d)(1) of Regulation S-K. We reissue prior comment 3.
        You may contact Mark Wojciechowski, Staff Accountant, at (202) 551-3759
or John
Cannarella, Staff Accountant, at (202) 551-3337 if you have questions regarding
comments on
the financial statements. You may contact John Coleman, Mining Engineer, at
(202) 551-3610
with questions regarding comments on the mineral property information. Please
contact Karl
Hiller, Branch Chief, at (202) 551-3686 with any other questions.



FirstName LastNameDaniel Dominguez                             Sincerely,
Comapany NameBuenaventura Mining Company Inc.
                                                               Division of
Corporation Finance
November 14, 2022 Page 2                                       Office of Energy
& Transportation
FirstName LastName
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