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                               August 21, 2020

       Leandro Garcia
       Chief Financial Officer
       Buenaventura Mining Company Inc.
       Las Begonia S 415 Floor 19
       San Isidro, Lima 27, Peru

                                                        Re: Buenaventura Mining
Company Inc.
                                                            Form 20-F for the
Fiscal Year ended December 31, 2019
                                                            Filed April 10,
2020
                                                            File No. 001-14370

       Dear Mr. Garcia:

              We have reviewed your filing 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.

       Form 20-F for the Fiscal Year ended December 31, 2019

       Property, Plants and Equipment
       Reserves, page 53

   1.                                                   We note that you
disclose total proven and probable reserves of 6.00 million ounces of
                                                        gold and 241.67 million
ounces of silver as of December 31, 2019 in the fourth and fifth
                                                        paragraphs on page 53.

                                                        Please expand your
disclosures to also summarize your copper and molybdenum reserves,
                                                        and to include a
reconciliation of the reserve information that you provide for consolidated
                                                        properties on page 54,
the Yanacocha property on page 56, and the Cerro Verde property
                                                        on page 87, to your
estimates of total proven and probable reserves. Please also specify
                                                        the reserves that are
attributable to your interests on separate lines within each tabulation,
                                                        including your
tabulations in Selected Financial Data on pages 4, 6 and 7.
 Leandro Garcia
FirstName LastNameLeandro Garcia
Buenaventura Mining Company Inc.
Comapany
August 21, NameBuenaventura
           2020             Mining Company Inc.
August
Page 2 21, 2020 Page 2
FirstName LastName
2.       Please provide footnote disclosures (3) through (10), as referenced in
the mining property
         column headers in the tabulations on page 54.
3.       We note your disclosure on page 56 of production and reserves
associated with the
         Yanacocha property, including specification of the attributable ounces
of gold production,
         attributable ounces of gold reserves, and attributable pounds of
copper. However, the
         attributable amounts appear to pertain to Newmont Mining rather than
Buenaventura.

         Please revise these disclosures as necessary to distinguish between
your interests and
         those attributable to other parties.
4.       We note that you have provided reserve disclosures for directly
operated properties on
         page 54 and the Yanachocha property on page 56. However, you have not
provided
         information for your interests in Cerro Verde under this heading,
although we note limited
         disclosure of copper production and reserves on pages 7 and 87.

         Please expand your disclosures under this heading to provide
comparable details of grade
         and content for the Cerro Verde copper, silver and molybdenum
reserves, and for the
         Yanachoca copper reserves mentioned on page 56.

         Please also disclose the extent to which the reserves quantified in
this section represent all
         of your interests in mining properties; and identify those for which
you have not provided
         such information along with your rationale.
5.       Please verify your computations of the average ore grade figures
presented for Cerro
         Verde on page 87, for leachable and millable ore, and provide us with
a reconciliation to
         the corresponding information in the underlying mine reports.
6.       With regard to the proven and probable reserves associated with the
Yanacocha and Cerro
         Verde properties, we will need to view the technical reports and other
information that
         establishes the legal, technical, and economic feasibility of the
materials designated as
         reserves, as outlined in paragraph (c) of Industry Guide 7.

         For example, this information should include the following:

                Property and geologic maps

                Description of the sampling and assaying procedures

                Drill-hole maps showing drill intercepts

                Representative geologic cross-sections and drill logs

                Description and examples of the cut-off calculation procedures

                Cutoff grades used for each category of reserves and resources
 Leandro Garcia
FirstName LastNameLeandro Garcia
Buenaventura Mining Company Inc.
Comapany
August 21, NameBuenaventura
           2020             Mining Company Inc.
August
Page 3 21, 2020 Page 3
FirstName LastName
                Justifications for the drill hole spacing used to classify and
segregate proven and
              probable reserves

                A detailed description of the procedures that have been
followed in estimating
              reserves

                Engineering or geological reports, including executive
summaries of feasibility
              studies or mine plans and cash flow analyses

                A detailed schedule of permitting and governmental approvals
required for the
              project, identifying the primary environmental and construction
approvals, and your
              current status relative to the schedule.

         These documents should be formatted as Adobe PDF files; and you may
ask to have this
         information returned by making a written request at the time it is
furnished, as provided in
         Rule 418(b) of Regulation C.

         Please contact our Mining Engineer, George K. Schuler, at (202)
551-3718 to arrange for
         the submission of the information outlined above.

         Please also provide the name and phone number for a technical person
whom he may
         call if he has technical questions about the reserves.
Note 2.4 - Summary of Significant Accounting Policies, page F-21
Note 2.4(q) - Revenue Recognition, page F-37

7.       We note your disclosure on page F-83 of metal sales revenues prior to
an adjustment for
         commercial deductions, which you describe on page 65 as refinery
charges and penalties
         incurred. Please expand your revenue recognition accounting policy
note to discuss the
         nature of the commercial deductions in relation to your metal sales or
sales performance
         obligations, and the reasons you present these as reductions to sales
revenues, based on
         your application of IFRS 15.

         In connection with the foregoing, please also address the following
points.

                Clarify how the accounting that you describe for provisional
prices and provisional
              price arrangements on page F-38 encompasses estimates of both
yield and price; and
              whether your accounting for embedded derivatives is limited to
provisional prices.

                Modify disclosures indicating that adjustments for some
provisional price items are
              being presented within "Net sales of goods," while others are
being reported as    fair
              value gain/losses on provisionally priced trade receivables,
as necessary to establish
              correlation with the provisional price components, and to
indicate where this second
              caption appears in your financial statements.
 Leandro Garcia
Buenaventura Mining Company Inc.
August 21, 2020
Page 4
                Address the requirements of paragraphs 56 through 59 of IFRS 15
relative to
              estimates of yield in your provisional price accounting.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Lily Dang at (202) 551-3867 if you have questions
regarding comments
on the financial statements and related matters. You may contact Ken Schuler at
(202) 551-3718
if you have questions regarding engineering comments. Please contact Karl
Hiller - Branch
Chief at (202) 551-3686 with any other questions.



FirstName LastNameLeandro Garcia                             Sincerely,
Comapany NameBuenaventura Mining Company Inc.
                                                             Division of
Corporation Finance
August 21, 2020 Page 4                                       Office of Energy &
Transportation
FirstName LastName