July 19, 2005



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 Fiscal Year Ended October 31, 2004
Filed June 30, 2005
Forms 10-QSB/A and 10-QSB for Fiscal Quarters Ended January 31,
2005
and April 30, 2005
Filed June 30, 2005 and June 20, 2005
      File No. 001-08397

Dear Mr. Scott Smith:

      We have reviewed your filings and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your documents. Where indicated, we think you should
revise your documents 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.


10-KSB/A for the Fiscal Year Ended October 31, 2004

General

1. Although you have filed an amendment reflecting some of the
revisions requested in our April 13, 2005 comment letter, you
should
provide a written response to each of the comments that were
included
in that letter.  Please submit all of your response letters on the
non-public section of Edgar at your earliest convenience.

2. We have reviewed your amended 10-KSB and were unable to locate
your expanded disclosure describing your exploration activities as
indicated in your explanatory language prefacing your amendment.
In
this regard we note your response in your letter dated April 7,
2005
that such disclosure would be included. Please expand your plan of
operation to include this disclosure.


10-Q for the Fiscal Quarter Ended April 30, 2005

3. We note that your net loss used to reconcile operating cash
flows
for the six months ended April 30, 2005 does not correspond to
your
net loss in your statement of operations.  Please revise your
statement of cash flows accordingly


Closing Comments

       As appropriate, please amend your filings 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
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested 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.

You may contact Jon Duersch at (202) 551-3719, if you have
questions
regarding comments on the financial statements and related
matters.
Please contact me at (202) 551-3686 with any other questions.
Direct
any correspondence to us at the following ZIP Code:  20549.


								Sincerely,



								Karl Hiller
								Branch Chief


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Mr. Scott L. Smith
Gold Standard, Inc.
July 19, 2005
page 1




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

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010