September 28, 2005

Mr. Raymond Pecoskie
President and CEO
Grandview Gold Inc.
400-56 Temperance Street
Toronto, Ontario, Canada, M5H 3V5

	RE:	Grandview Gold Inc.
		Amendment No. 1 to Registration Statement on Form 20-F
		Filed on August 18, 2005
		File No. 0-51303

Dear Mr. Pecoskie:

      We have reviewed your filing and your response letter dated
August 18, 2005 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 information so we may better
understand your disclosure.  After reviewing this information, we
may
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 any other aspect of
our
review.  Feel free to call us at the telephone numbers listed at
the
end of this letter.

Form 20-F

Capitalization and Indebtedness, page 3

1. Update your Capitalization table as of a date no earlier than
60
days prior to the filing of the registration statement.  See Item
3.B.
of Form 20-F.

Risk Factors, page 4
2. If material, provide a risk factor that addresses the
possibility
that you may be deemed a Passive Foreign Investment Company, as
provided in your taxation discussion.  Briefly explain that U.S.
investors who invest in Grandview Gold Inc. will be subject to
U.S.
taxation at possibly adverse or higher rates and under a system
that
may be more complicated and unfamiliar to them.
3. Some of your subheadings merely state a fact about your
business
without fully describing the risks associated with that fact.  For
example, we note "Gold Prices are Volatile and Could Decline" and
"We
are Dependent Upon the Continuing Services of Management."  Where
you
have not already done so, please revise each of your subheadings
to
ensure that they disclose the specific risk or risks that you are
discussing in the text.

Development Stage Company - Exhibit 99.2
4. In as much as the interim period February 28, 2005 financial
statements included in Exhibit 99.2 are a required part of Form
20-F
(see Item 8.A.5 of Form 20-F), these financial statements should
be
revised to remove all development stage company references.  We
note
your response to our prior comment #20.
Closing Comments

	We remind you that the Form 20-F registration statement
becomes
effective automatically under the Exchange Act 60 days from the
date
of filing, and the Exchange Act reporting requirements become
operative at that time.

      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
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.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing
includes all information required under the Securities Exchange
Act of
1934 and that they have provided all information investors require
for
an informed investment 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.

	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;

* 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.

      Direct questions relating to the engineering comments to
Roger
L. Baer at (202) 551-3705.  Direct questions relating to the
accounting comments to John Weitzel at (202) 551-3731 or, in his
absence, to Barry Stem, Senior Assistant Chief Accountant at (202)
551-3763.  Direct questions relating to all other disclosure
issues to
Jason Wynn at (202) 551-3756 or, in his absence, to the
undersigned,
at (202)551-3685.  Direct any correspondence to us at the
following
ZIP Code: 20549-7010.

      Sincerely,


									Tangela S. Richter
									Branch Chief


cc:	R. Baer
	B. Stem
      J. Weitzel
      J. Wynn
      S. Min

      Via facsimile
      Mr. James Berns
      (212) 332-3315

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Mr. Raymond Pecoskie
Grandview Gold Inc.
September 28, 2005
page 1



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

         DIVISION OF
CORPORATION FINANCE
    MAIL STOP 7010