April 13, 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
		Supplemental response dated April 7, 2005
      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

Management`s Discussion and Analysis or Plan of Operation

1. We note your response to prior comment 3, in which you indicate
a
preference for limiting disclosure of the nature of your
exploration
activities to future filings.  Since you will need to amend your
filing for the other matters identified, please also include
expanded
disclosure on this subject in your amendment.  The draft amendment
that you submitted as correspondence on April 7, 2005 should be
further revised to address all comments in this letter, and then
filed as a public document.  Please contact us regarding this
matter
if you require further clarification.

Financial Statements, page F-2

		General

2. We have read your response to prior comment 5, and are unable
to
agree that your business has evolved beyond that of an exploratory
stage company.  Although you indicate that planned principal
operations have commenced, there appears to have been no
significant
revenue generated by the company in almost 10 years.  Your
suggestion
that your business plan is limited to the evaluation of geological
sites, with no provision to ever conduct extraction operations,
appears contrary to your disclosures under the heading of Business
Development, stating that you were organized "...for the purpose
of
engaging in the exploration, production and sale of gold."
Similarly, your disclosure under Liquidity and Capital Resources,
stating "The Company is attempting to raise additional funds and
is
searching for joint venture partners with which it can recommence
operations..." is indicative of an exploratory stage enterprise.
We
encourage you to read the guidance in paragraphs 8 and 9 of SFAS
7,
describing various characteristics of a development stage
enterprise.
As previously explained, since you are in an extractive industry,
and
have no mineral reserves to report, the term exploratory stage
must
be used instead of development stage, in describing the company.
We
reissue prior comment 5.  Please call us to discuss this matter at
your earliest availability.


  10-Q for the period ended January 31, 2004

General

3. Please revise your interim report as necessary to comply with
all
applicable comments written on your annual report above.  Your
revisions should include enhanced disclosure to MD&A, and
cumulative,
inception-to-date information, in your financial statements.

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.
April 13, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE