United States securities and exchange commission logo





                             September 15, 2020

       David Soares
       Chief Financial Officer
       Kirkland Lake Gold Ltd.
       200 Bay Street, Suite 3120
       Toronto, Ontario M5J2J1
       Canada

                                                        Re: Kirkland Lake Gold
Ltd.
                                                            Form 40-F for the
Fiscal Year Ended December 31, 2019
                                                            Filed March 31,
2020
                                                            File No. 001-38179

       Dear Mr. Soares:

              We have reviewed your filing 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.

       Form 40-F for the Fiscal Year Ended December 31, 2019 Filed March 31,
2020

       Exhibit 99.1 Annual Information Form
       Material Properties
       The Macassa Mine, page 63

   1.                                                   We note your disclosure
of the results of an economic analysis that appears to include
                                                        resource ounces based
upon mineral resource conversion factors for measured and
                                                        indicated resources and
inferred resources. Please tell us the level of study contemplated
                                                        considering the
inclusion of measured, indicated, and inferred resources.
   2.                                                   As your economic study
includes inferred resources, please tell us if cautionary language
                                                        is required
accompanying the results of the study under National Instrument 43-101.
 David Soares
Kirkland Lake Gold Ltd.
September 15, 2020
Page 2

        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.

       You may contact John Coleman at 202-551-3610 or Craig Arakawa at
202-551-3650 if
you have questions regarding comments.



FirstName LastNameDavid Soares                            Sincerely,
Comapany NameKirkland Lake Gold Ltd.
                                                          Division of
Corporation Finance
September 15, 2020 Page 2                                 Office of Energy &
Transportation
FirstName LastName