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                              October 23, 2020

       Leandro Garcia
       Chief Executive 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
                                                            Response Letter
dated October 5, 2020

       Dear Mr. Garcia:

              We have reviewed your October 5, 2020 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
       August 21, 2020 letter.

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

       Property, Plants and Equipment Reserves
       Reserves, page 53

   1.                                                   We note that you have
provided various details pertaining to estimates of proven and
                                                        probable reserves, and
have agreed to provide incremental disclosures and
                                                        revisions regarding
such details, in response to prior comments one through four. Please
                                                        clarify the extent to
which the content of your prior responses to each of these comments
                                                        represents the specific
revisions that you propose to include in future filings, and submit
                                                        any further content
that would together constitute all of the incremental disclosures and
                                                        revisions that you
believe would address our concerns.
 Leandro Garcia
Buenaventura Mining Company Inc.
October 23, 2020
Page 2
      Please also submit the revisions that you propose to address the
following additional
      points regarding your prior responses.

             We note that you indicate in response to prior comment one that
you would include a
           reconciliation for the consolidated reserve information referenced
in the fourth and
           fifth paragraphs on page 53, although this was not submitted with
your reply. Please
           submit for our review the tabulation that you would provide to
indicate the
           composition of the 6.00 million ounces of gold, 241.67 million
ounces of silver, 4.8
           million metric tons of copper and 0.6 million metric tons of
molybdenum, including
           separate lines for the attributable amounts that correspond to the
separate property
           tabulations that will also be provided in the filing.

             We note that you indicate in response to prior comment three, that
you would revise
           the tabulation on page 56 to correct an error and to include the
attributable gold
           reserves associated with the Yanacocha property, although you have
not addressed
           the disclosures in the first paragraph on that page, referencing
attributable production
           and reserves of gold, and attributable reserves of copper, which do
not appear to
           correlate with your interests. Please submit the revisions that you
propose to correct
           the various attributable amounts in this disclosure.
Financial Statements
Note 2.4 - Summary of Significant Accounting Policies
Note 2.4(q) - Revenue Recognition, page F-37

2.    We note that you have agreed to provide incremental disclosures in
response to prior
      comment seven regarding your commercial deductions and provisional price
adjustments.
      Please submit for our review the specific language that you propose to
include in future
      filings and which you believe will adequately clarify your accounting and
presentation
      with regard to these matters.
        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 any engineering questions. Please contact Karl Hiller - Branch
Chief at (202) 551-
3686 with any other questions.



                                                             Sincerely,
FirstName LastNameLeandro Garcia
                                                             Division of
Corporation Finance
Comapany NameBuenaventura Mining Company Inc.
                                                             Office of Energy &
Transportation
October 23, 2020 Page 2
cc:       Marcelo Mottesi - External Counsel
FirstName LastName