March 11, 2005

via facsimile and U.S. mail
Scott L. Smith
President and Chief Executive Officer
(Principal Financial Officer)
Gold Standard, Inc.
136 South Main Street, Suite 712
Salt Lake City, Utah 84101


	Re:	Gold Standard, Inc.
		Form 10-KSB/A, for the year ended October 31, 2004
      File No. 001-08397

Dear Mr. Scott L. Smith:

      We have reviewed the above filing and have the following
accounting comments.  We have limited our review to only the
matters
addressed below and will make no further review of your document.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.











10-KSB/A for the year ended October 31, 2004

General

1. Please revise your filing to include explanatory language,
preceding Item 1, identifying the reasons for your amendment, and
the
corresponding sections that have changed.

2. Please include page numbers on all future filings, including
any
amendments that are necessary.

Management`s Discussion and Analysis or Plan of Operation

3. We are unable to locate any disclosure in your filing
describing
the exploration activities that are associated with your
exploration
costs.  Please expand your disclosure to explain these activities
and
to indicate whether your historical expenditures are indicative of
any ongoing exploration activities.

Report of Independent Registered Public Accounting Firm

4. We note that the auditor associated with the audit opinion
included in your filing has not been identified.  The report is
not
in compliance with Rule 2-02 of Regulation S-X.  Please amend your
filing to replace that report with a signed audit opinion.

Financial Statements, page F-2

		General

5. We note that although there have been no significant revenues
generated from your operations you have not characterized your
company as an "exploratory stage" entity. Therefore, it appears
you
will need to revise your financial statement presentation to
provide
the appropriate cumulative amounts from the company`s inception to
comply with paragraph 11 of SFAS 7.  Additionally, since you are
in
an extractive industry, it will be necessary to revise the
disclosures and labeling throughout your document to characterize
the
company as an "exploratory stage" entity, rather than a
"development
stage" entity, as that term has specific meaning within the
extractive industry which describes an advanced mining activity in
which proved reserves have been determined.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
amendments to expedite our review.  Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filing(s);

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and

	the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Jon Duersch at (202) 942-1761 or Karl Hiller
at
(202) 942-1981 if you have questions regarding comments on the
financial statements and related matters.  Please contact me at
(202)
942-1870 with any other questions.  Direct all correspondence to
the
following ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director
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Gold Standard, Inc.
March 11, 2005
Page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE