March 4, 2025

Tony Giardini
President and Chief Executive Officer
Trilogy Metals Inc.
Suite 901, 510 Burrard Street
Vancouver, British Columbia
Canada, V6C 3A8

       Re: Trilogy Metals Inc.
           Registration Statement on Form S-3
           Filed February 20, 2025
           File No. 333-285072
Dear Tony Giardini:

       We have conducted a limited review of your registration statement and
have the
following comments.

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments.

Registration Statement on Form S-3 filed February 20, 2025
General

1.     We note that your registration statement incorporates by reference your
Form 10-K
       for the fiscal year ended November 30, 2024, which in turn incorporates
by reference
       certain Part III information from a definitive proxy statement that you
have not yet
       filed. Please be advised that we cannot accelerate the effective date of
your
       registration statement until you have amended your Form 10-K to include
the Part III
       information or have filed a proxy statement which includes such
information. For
       guidance, please refer to Question 123.01 of the Securities Act Forms
Compliance and
       Disclosure Interpretations.
 March 4, 2025
Page 2
2.     We note that you did not include a statement incorporating future
Exchange Act
       filings prior to effectiveness of the registration statement. Please
revise accordingly or
       ensure that you incorporate by reference each specific filing prior to
requesting
       acceleration of effectiveness. For guidance, please refer to Question
123.05 of the
       Securities Act Forms Compliance and Disclosure Interpretations.

        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.

       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.

       Please contact Anuja Majmudar at 202-551-3844 or Daniel Morris at
202-551-3314
with any other questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Energy
& Transportation
cc:   Kimberly Anderson