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                            March 2, 2022

       Corrado De Gasperis
       Chief Executive Officer
       Comstock Mining, Inc.
       117 American Flat Road
       Virginia City, NV 89440

                                                        Re: Comstock Mining,
Inc.
                                                            Form 10-K for the
year ended December 31, 2020
                                                            Filed March 10,
2021
                                                            Form 10-Q for the
quarterly period ended September 30, 2021
                                                            Filed November 9,
2021
                                                            Response dated
February 2, 2022
                                                            File No. 001-35200

       Dear Mr. De Gasperis:

              We have reviewed your February 2, 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
       December 23, 2021 letter.

       Form 10-Q for the quarterly period ended September 30. 2021

       Item 1. Financial Statements
       2. Acquisition and Investments, page 16

   1.                                                   Please refer to comment
4 in our letter dated December 23, 2021. Based on the
                                                        information provided at
Exhibit A of your letter dated February 2, 2022, it appears that
                                                        summarized financial
information for your equity method investments in the aggregate
                                                        was required in your
financial statements for the quarter ending September 30, 2021.
                                                        Rule 8-03(b)(3) of
Regulation S-X requires summarized information if the significance of
                                                        any individual or any
combination of investees exceeds the 20% thresholds using any of
 Corrado De Gasperis
Comstock Mining, Inc.
March 2, 2022
Page 2
         the three tests in Rule 1-02(w) of Regulation S-X. Additionally, ASC
323-10-50-3c states
         that summarized information may be necessary if equity method
investments are material
         in relation to the financial position and results of operations of an
investor. Please revise
         your disclosures accordingly. Please also disclose which investments
are accounted for
         using a lag basis.
5. Assets Held for Sale, page 23

2.       We note your response to prior comment 5 does not adequately explain
how the Silver
         Spring properties continue to qualify for the exception to the
one-year requirement after
         more than two years have passed since the asset group was classified
as held for sale.
         Please provide a detail analysis of ASC 360-10-45-11(c) that clearly
describes the events
         or circumstances that arose during the two year period that
contributed to the delay in sale
         and the specific actions you have taken to respond to these events or
circumstances to
         allow you to conclude that the properties continue to be available for
immediate sale in its
         present condition and that the sale continues to be probable. Please
further describe any
         price reductions or renegotiations with Sierra Springs and the reasons
why you believe the
         price continues to be reasonable in relation to the fair value of the
Silver Spring
         properties.
Item 2. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Comparative Financial Information, page 51

3.       We note your response to prior comment 7. Please explain how the
one-time $812,500
         contribution payment was originally recorded and identify its location
and balance in the
         balance sheet as of September 30, 2021. In addition, please explain
why the full amount of
         this capital contribution payment was recognized immediately against
expenses whereas
         your recurring monthly and annual capital contributions are recognized
over the term of
         the operating agreement on a straight line basis.
       You may contact Brian McAllister at (202) 551-3341 or Craig Arakawa,
Accounting
Branch Chief, at (202) 551-3650 if you have questions regarding comments on the
financial
statements and related matters.



FirstName LastNameCorrado De Gasperis                          Sincerely,
Comapany NameComstock Mining, Inc.
                                                               Division of
Corporation Finance
March 2, 2022 Page 2                                           Office of Energy
& Transportation
FirstName LastName