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<SEC-DOCUMENT>0001062993-08-000076.txt : 20080411
<SEC-HEADER>0001062993-08-000076.hdr.sgml : 20080411
<ACCEPTANCE-DATETIME>20080110132619
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0001062993-08-000076
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20080110

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			NEW JERSEY MINING CO
		CENTRAL INDEX KEY:			0001030192
		STANDARD INDUSTRIAL CLASSIFICATION:	GOLD & SILVER ORES [1040]
		IRS NUMBER:				820490295
		STATE OF INCORPORATION:			ID
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		89 APPLEBERG RD
		STREET 2:		PO BOX 1019
		CITY:			KELLOGG
		STATE:			ID
		ZIP:			83837
		BUSINESS PHONE:		208-783-3331

	MAIL ADDRESS:	
		STREET 1:		89 APPLEBERG ROAD
		STREET 2:		PO BOX 1019
		CITY:			KELLOGG
		STATE:			ID
		ZIP:			83837
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.htm
<TEXT>
<!DOCTYPE HTML PUBLIC "07 Response to SEC Review Comments V2.7.pdf">


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<P align=center><B><FONT size=4>New Jersey Mining Company </FONT></B><BR>P.O.
BOX 1019 <BR>KELLOGG, ID 83837 <BR>(208) 783-3331 [PHONE OR FAX] <BR></P>
<P align=right>December 19, 2007 <BR>Revised January 10, 2008 <BR></P>
<P align=justify>Jill S. Davis, Branch Chief <BR>United States Securities and
Exchange Commission <BR>Division of Corporation Finance <BR>100 F Street, NE
<BR>Mail Stop 7010 <BR>Washington, D.C. 20549-7410 <BR></P>
<P align=justify>Dear Ms. Davis: </P>
<P align=justify>Following are responses to SEC comments on the Company&#146;s 2006
Form 10-KSB filed March 28, 2007and 2007 Form 10QSB for Fiscal Quarter Ended
September 30, 2007 filed November 13, 2007 which were faxed to our office on
December 19, 2007. We have discussed our planned responses with internal staff
and with our auditors and submit the following responses: I believe we have
responded fully to the comments made by SEC. A marked filing of the proposed
revisions to the Form 10-KSB is included for reference. </P>
<P align=center><B><U>Form 10-KSB Filed March 28, 2007</U></B><B> </B></P>
<P align=justify><B><U>Report of Independent Registered Public Accounting firm,
page 27</U></B><B> </B></P>
<TABLE
style="BORDER-COLOR: black; FONT-SIZE: 10pt; BORDER-COLLAPSE: collapse; "
cellSpacing=0 cellPadding=0 width="100%" border=0 BCLLIST>

  <TR>
    <TD vAlign=top width="5%">1. </TD>
    <TD>
      <P align=justify>Comment: We note your auditors opine on the statements of
      operations, changes in stockholders&#146; equity and accumulated comprehensive
      income, and cash flows for the years ended December 31, 2005 and 2006.
      Please revise to obtain a report from your independent public accounting
      firm that refers also to the period from inception (July 18, 1996) through
      December 31, 2006 for the applicable financial statements.</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD>
      <P align=justify>Response: We refer you to the following comment received
      by the Company from the SEC in a letter dated May 17,
  2005:</P></TD></TR></TABLE>
<P style="MARGIN-LEFT: 10%" align=justify><I>We note that you present the
cumulative results of operations, changes in stockholders&#146; equity and statements
of cash flows for the period from inception on July 18, 1996 to December 31,
2004 as audited. However, your auditors indicate in their report that they did
not audit the portion of those cumulative totals for the period from inception
on July 18, 1996 to December 31, 2002. Since there is no disclosure or labeling
to suggest the information related to the period from inception on July 18, 1996
to December 31, 2002, is unaudited, it will be necessary to amend your filing to
include the other auditor&#146;s report, provided that auditor is willing to reissue
the opinion, or to otherwise label such information as unaudited until you are
able to make other arrangements. Please contact us, </I></P>
<P align=center>1 </P>
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<P style="MARGIN-LEFT: 10%" align=justify><I>along with you independent
auditors, to discuss the requested items above prior to submitting your
response. </I></P>
<P style="MARGIN-LEFT: 5%" align=justify>As a result of this comment and
telephonic conversation with the SEC, the December 31, 2004 10KSB financial
statements were updated to present the statements of operations, changes in
stockholders&#146; equity and cash flows to label cumulative results as unaudited. In
addition, references to these statements were removed from the auditor&#146;s report.
</P>
<P style="MARGIN-LEFT: 5%" align=justify>We have consistently presented this
information as &#147;unaudited&#148; and believe it still is correct to continue to do so.
</P>
<P align=justify><B><U>Statement of Operations, page 30</U></B><B> </B></P>
<TABLE
style="BORDER-COLOR: black; FONT-SIZE: 10pt; BORDER-COLLAPSE: collapse; "
cellSpacing=0 cellPadding=0 width="100%" border=0 BCLLIST>

  <TR>
    <TD vAlign=top width="5%">2. </TD>
    <TD>
      <P align=justify>Comment: We note your presentation of timber sales as a
      net amount under Other income/expense. Please tell us why you believe it
      is appropriate to report your timber sales on a net basis instead of a
      gross basis and provide us with the gross amounts for all periods
      presented. If applicable, please add an accounting policy footnote for
      these types of transactions or tell us why you do not believe this
      disclosure is necessary.</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD>
      <P align=justify>Response: We believe that it is appropriate to report
      Timber sales as a net amount under Other income/expense because it is not
      a normal part of our business and, typically, it is immaterial in amount.
      We have added an accounting policy footnote on page 35 to describe these
      types of transactions. Upon review of our figures, the 2005 reported
      amount was in fact gross income for timber revenue in 2005-$51,695, the
      accompanying expense $11,237 was included with General and Administrative
      expense. These amounts are 8.75% and 1.9% of net loss respectively. We
      have adjusted our Timber sales net amount and General and Administrative
      amounts to reflect the net Timber amount of $40,458 accordingly. In 2006
      Timber Sales was reported as a net amount {$800} in the other
      income/expense line. Gross amounts for 2006 were revenue $2,517 and
      expense $3,317. These amounts were 0.25% and 0.33% of net loss
      respectively.</P></TD></TR></TABLE>
<P align=justify><B><U>Note 1. Description of Business, page 35</U></B><B>
</B></P>
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  <TR>
    <TD vAlign=top width="5%">3. </TD>
    <TD>
      <P align=justify>Comment: We note your disclosure that &#147;The Company has
      started minor production from high grade reserves located near the surface
      with the strategy to generate cash to be used for additional exploration
      to discover major mineral resources on its properties. The Company has not
      yet developed sufficient reserves to justify investment in a major mine,
      thus it remains in the development stage.&#148; Based on this disclosure,
      please tell us why you believe it is appropriate to report revenue from
      the sales of gold and concentrate rather than Income earned during the
      development or exploration stage.</P></TD></TR></TABLE>
<P align=center>2 </P>
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<P style="MARGIN-LEFT: 5%" align=justify>Response: We agree that the terminology
&#147;Income earned during the development stage&#148; is more appropriate and have
changed the statement of operations and revenue policy footnote accordingly.
</P>
<P align=justify><B><U>Note 5. Mineral Properties, page 41</U></B><B> </B></P>
<TABLE
style="BORDER-COLOR: black; FONT-SIZE: 10pt; BORDER-COLLAPSE: collapse; "
cellSpacing=0 cellPadding=0 width="100%" border=0 BCLLIST>

  <TR>
    <TD vAlign=top width="5%">4. </TD>
    <TD>
      <P align=justify>Comment: We note the column entitled Deferred Costs in
      the table of mineral properties and deferred development costs. Please
      tell us and expand your footnote to explain the nature of the deferred
      costs and when they were incurred.</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD>
      <P align=justify>Response: Upon further reflection, we determined that
      there is no distinction between Deferred Costs and Capitalized Development
      and we have combined these two columns as &#147;Deferred Development&#148; in the
      10KSB for 2006 and expanded our accounting policy footnote on page 37 to
      specifically identify deferred development costs.</P></TD></TR></TABLE>
<P align=justify><B><U>Engineering Comments</U></B><B> </B></P>
<P align=justify><B><U>Reserves, page 12</U></B><B> </B></P>
<TABLE
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  <TR>
    <TD vAlign=top width="5%">5. </TD>
    <TD colSpan=2>
      <P align=justify>Comment: We note that you have reported combined proven
      and probable reserve categories. Note that Industry Guide 7, provides that
      reserves may be combined as &#147;proven and probable&#148; only if proven and
      probable reserves cannot be readily segregated. Please separate your
      proven and probable reserves or include a statement that they cannot be
      readily segregated.</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD colSpan=2>
      <P align=justify>Response: The proven and probably reserves cannot be
      readily separated. We have added a statement to this effect in the
      10KSB.</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD vAlign=top width="5%">6. </TD>
    <TD colSpan=2>
      <P align=justify>Comment: We note that you have measured your proven and
      probable reserves using the year-end spot price of Gold. It is the staff&#146;s
      position that reserves should be based on the following:</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD vAlign=top width="5%">
      <LI></LI></TD>
    <TD>
      <P align=justify>A &#147;final&#148; or &#147;bankable&#148; feasibility study is required to
      meet the requirements to designate reserves under Industry Guide
  7.</P></TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD vAlign=top width="5%">
      <LI></LI></TD>
    <TD>
      <P align=justify>A historic three year average price is to be used in any
      reserve or cash flow analysis to designate reserves.</P></TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD vAlign=top width="5%">
      <LI></LI></TD>
    <TD>
      <P align=justify>To meet the &#147;legal&#148; part of the reserve definition, the
      primary environmental analysis or document should have been submitted to
      governmental authorities.</P></TD></TR></TABLE>
<P style="MARGIN-LEFT: 5%" align=justify>Please revise your reserve estimates
accordingly. </P>
<P style="MARGIN-LEFT: 5%" align=justify>Response: We have revised our reserve
calculations using an historic three-year gold price as per your request. </P>
<P align=center>3 </P>
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<P align=center><B><U>Form 10-QSB for the Fiscal Quarter Ended September 30,
2007</U></B><B> </B></P>
<P align=justify><B><U>Controls and Procedures, page 11</U></B><B> </B></P>
<TABLE
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  <TR>
    <TD vAlign=top width="5%">7. </TD>
    <TD>
      <P align=justify>Comment: You disclose that your &#147;disclosure controls and
      procedures were effective as of September 30, 2007, in ensuring that all
      material information required to be filed in this quarterly report has
      been made known to them in a timely fashion.&#148; Item 307 of Regulation S-B
      requires you to disclose your officer&#146;s conclusions regarding the
      effectiveness of your disclosure controls and procedures as that term is
      defined in Rule 13a-15(e) of the Exchange Act. The definition in rule
      13a-15(e) is more comprehensive than that included in your disclosure.
      Specifically, the term disclosure controls and procedures also includes
      controls that are &#147;&#133;designed to ensure that information required to be
      disclosed by the issuer in the reports that it files or submits under the
      Act is recorded, processed, summarized and reported, within the time
      periods specified in the Commission&#146;s rules and forms.&#148; Your officer&#146;s
      conclusion does not state whether your disclosure controls and procedures
      are effective at accomplishing these items. Please revise your officers
      conclusion in future filings to state whether you disclosure controls and
      procedures are effective at accomplishing all of the items included within
      the definition of disclosure controls and procedures as defined in Rule
      13a-15(e) of the Exchange Act.</P></TD></TR>
  <TR>
    <TD width="5%">&nbsp;</TD>
    <TD>&nbsp;</TD></TR>
  <TR>
    <TD width="5%"></TD>
    <TD>
      <P align=justify>Response: We will, in future filings, state whether or
      not our disclosure controls and procedures are effective at accomplishing
      all of the items included within the definition of disclosure controls and
      procedures as defined in Rule 13a-15(e) of the Exchange
  Act.</P></TD></TR></TABLE>
<P align=justify><B><U>Closing Comments</U></B><B> </B></P>
<P align=justify>In accordance with the Staff&#146;s request, we acknowledge that:
</P>
<UL style="TEXT-ALIGN: justify">
  <LI>The Company is responsible for the adequacy and accuracy of the disclosure
  in its filings with the Commission;
  <LI>Staff comments or changes to disclosure in response to Staff comments do
  not foreclose the Commission from taking any action with respect to the
  filings; and
  <LI>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. </LI></UL>
<P align=justify>We hope that our response adequately addresses the Staff&#146;s
comments and respectfully request that the Staff advise us at its earliest
convenience if the Staff believes that any of the responses set forth in this
letter are incomplete or unsatisfactory or if the Staff has any further comments
on our filings. </P>
<P align=justify>Sincerely, </P>
<P align=justify>Fred W. Brackebusch<BR> President </P>
<P align=center>4 </P>
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