July 12, 2005

via facsimile and U.S. mail

Mr. Terry C. Turner
President, Chairman, and Chief Executive Officer
12401 South 450 East, Building D1
Salt Lake City, Utah  84020

	Re:	Golden Eagle International Inc.
		Form 10-K, filed April 15, 2005
		Response Letter dated, May 25, 2005
		File No. 000-23726

Dear Mr. Turner:

	We have reviewed your filings and have the following
comments.
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.

Efforts to Obtain Additional Production, page 15 & Buen Futuro
Reserves, page 20

1. Industry Guide 7 requires ore reserves to be that part of a
mineral deposit that can be economically and legally extracted or
produced at the time of the reserve determination.  It also
requires
that the quantities for proven reserves are computed from the
dimensions revealed in outcrops, trenches, workings or drill holes
and the quality of the ore is computed from the results of
detailed
sampling.  The sites for inspection, sampling, and measurement are
spaced so closely and the geologic character is so well defined
that
the size, shape, depth, and mineral content of reserves are well-
established.  The degree of assurance for probable reserves,
although
lower than that for proven reserves, is high enough to assume
continuity between points of observation.

The "Technical Geological Report - Geology, Resources and Reserves
at
the Cangalli Gold Mine" and the "Technical Report - Geology,
Mineral
Resource & Reserve Buen Futuro" are not "final" or "bankable"
feasibility reports and do not demonstrate economic mining
operations
are possible.  The information required to demonstrate proven &
probable reserves was not provided in these reports.  Many key
parameters, such as the sample spatial locations, in-situ & bulk
densities, reproducible and representative sampling procedures
with
quality assurance & quality controls (QA/QC), metallurgical
recoveries, and mining costs were assumed, not demonstrated.
Remove
all reserve estimates from the filing.

Closing Comments

      As appropriate, please amend your registration statements in
response to these comments.  You may wish to provide us with
marked
copies of the amendments to expedite our review.  Please furnish a
cover letter with your amendments 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
amendments and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.  Please file your correspondence on EDGAR.  Please
understand that we may have additional comments after reviewing
your
response to our comments.

      You may contact George (Ken) Schuler, mining engineer, at
(202)
551-3718 or, in his absence, Roger Baer, mining engineer, at (202)
551-3705, if you have questions regarding engineering comments.
Please contact me at (202) 551-3740 with any other questions.
Direct
all correspondence to the following ZIP code:  20549-7010.



							Sincerely,



							H. Roger Schwall
							Assistant Director
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Mr. Terry C. Turner
Golden Eagle International Inc.
July 12, 2005
Page 2



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 - 7010

         DIVISION OF
CORPORATION FINANCE