June 17, 2019

Paul A. Schmidt
Chief Financial Officer
GOLD FIELDS LTD
150 Helen Road
Sandown, Sandton, 2196
South Africa

       Re: GOLD FIELDS LTD
           FORM 20-F
           Filed March 29, 2019
           File No. 001-31318

Dear Mr. Schmidt:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 20-F

Further Information/Reserve Statement, page 68

1.    Proven and probable reserves are disclosed for your Salares Norte, Cerro
Corona, and
      Demang properties. Please forward to our engineer as supplemental
information and not
      as part of your filing, your information that establishes the legal,
technical, and economic
      feasibility of your materials designated as reserves, as required by
Industry Guide 7(c).

      To minimize the transfer of paper, please provide the requested
information on a CD or a
      flash drive, formatted as Adobe PDF files and provide the name and phone
number for a
      technical person our engineer may call, if he has technical questions
about your reserves.

      In the event your company desires the return of this supplemental
material, please make a
      written request with the letter of transmittal and include a pre-paid,
pre-addressed shipping
 Paul A. Schmidt
GOLD FIELDS LTD
June 17, 2019
Page 2
         label to facilitate the return of the supplemental information. Please
note that you may
         request the return of this information pursuant to the provisions of
Rule 12b-4 of the
         Exchange Act.

         If there are any questions concerning the above request, please phone
Mr. George K.
         Schuler, Mining Engineer at (202) 551-3718.


       In closing, 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.

        Please contact George K. Schuler, Mining Engineer at (202) 551-3718 or
Pam Howell
at (202) 551-3357 with any questions.



                                                               Sincerely,
FirstName LastNamePaul A. Schmidt
                                                               Division of
Corporation Finance
Comapany NameGOLD FIELDS LTD
                                                               Office of
Beverages, Apparel and
June 17, 2019 Page 2                                           Mining
FirstName LastName