Seabridge Gold Inc.






February 11, 2009


United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 7010
100 F Street N.E.
Washington D.C., USA
20549-7010

Attention: H. Roger Schwall


Re:      Seabridge Gold Inc.
         Your letter dated February 3, 2009


Dear Sirs;

We hereby respond to the comments made in your letter dated February 3, 2009
regarding our Form 20-F filing for the year ended December 31, 2007, in the
matching order of the comments.


      1. Interest of Management in Certain Transactions

      We hereby confirm that we will include disclosure meeting the requirements
      of Item 7.B in future applicable filings. We provide below an example of
      the disclosure we intend to use:

      B. Interest of Management in Certain Transaction

      During the fiscal years ended December 31, 2008, 2007 and 2006, Mintec,
      Inc., a private company controlled by Fred Banfield, a Director of
      Seabridge, was paid $_______, $33,300 and $33,900, respectively, for
      technical services provided by his company related to the mineral
      properties. These technical services were for consulting and computer
      software for geologic modeling, reserve estimation, mine planning and
      database management. The Company negotiated the agreement at arms length,
      after the Company reviewed all available software in the marketplace and
      determined that the agreement negotiated with Mintec was the most cost
      effective available.

      During the fiscal years ended December 31, 2008, 2007, and 2006, Suma
      Investments Inc., a private company controlled by James Anthony, the
      Chairman and a director of Seabridge was paid $_______, $360,000, and
      $144,000, respectively, for corporate consulting services rendered. The
      Company negotiated the agreement at arms length, after the Company
      reviewed available compensation data from comparable companies and
      determined that the agreement negotiated with Suma Investments was
      reasonable.

- --------------------------------------------------------------------------------
       106 Front Street East, Suite 400, Toronto, Ontario, Canada M5A 1E1
   Telephone: (416) 367-9292 Facsimile: (416) 367-2711 info@seabridgegold.net
                              www.seabridgegold.net





      During the fiscal years ended December 31, 2008, 2007, and 2006, Eliseo
      Gonzalez-Urien, a director of Seabridge was paid $_______, $17,300 and
      $18,000, respectively, for geological consulting services rendered. The
      Company negotiated the agreement at arms length, after the Company
      reviewed available compensation data from comparable consulting firms and
      determined that the agreement negotiated with Mr. Gonzalez-Urien was
      reasonable.

      Pan Atlantic Bank and Trust Ltd. has been an investor in two convertible
      debt offerings and two private placements of common shares by Seabridge.
      Pan Atlantic Bank and Trust Ltd.'s sole shareholder is FCMI Financial
      Corporation.

      None of the Company's interests in its mineral properties were acquired
      from affiliates.


      2. Management's Report on Internal Control over Financial Reporting

      We hereby confirm that in future filings we will provide either a cross
      reference in Item 15 to our discussion of changes in our internal control
      over financial reporting, or provide a separate statement fulfilling our
      US disclosure obligation to provide a discussion of changes in our
      internal control over financial reporting.


Should you have any questions about the responses in this letter, please contact
our US securities counsel Bruce Rich at 212-238-8895 or the undersigned.


Yours truly,

/s/ Roderick Chisholm
Roderick Chisholm
Corporate Secretary