February 25, 2020

Rick Havenstrite
Chief Executive Officer
Desert Hawk Gold Corp.
1290 Holcomb Avenue
Reno, NV 89502

       Re: Desert Hawk Gold Corp.
           Registration Statement on Form S-1
           Filed February 12, 2020
           File No. 333-236398

Dear Mr. Havenstrite:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-1

General

1.     Based on the filing date of this registration statement, it appears your
effective date could
       be after 45 days but within 90 days of your fiscal year end. As it
appears you may not
       satisfy the conditions of Item 8-08(b) of Regulation S-X, please file
your
       audited financial statements for the fiscal year ended December 31,
2019, prior to the
       requested date of effectiveness of your registration statement, or
provide your analysis of
       why you believe you are not required to update your financial
statements. For additional
       guidance, please consider Section 1220.3 of the Division's Financial
Reporting Manual.
        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.
 Rick Havenstrite
Desert Hawk Gold Corp.
February 25, 2020
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

      You may contact Irene Barberena-Meissner, Staff Attorney, at 202-551-6548
or Kevin
Dougherty, Staff Attorney, at 202-551-3271 with any questions.



                                                           Sincerely,
FirstName LastNameRick Havenstrite
                                                           Division of
Corporation Finance
Comapany NameDesert Hawk Gold Corp.
                                                           Office of Energy &
Transportation
February 25, 2020 Page 2
cc:       Ron Vance, Esq.
FirstName LastName