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                                October 27, 2021

       Sam Ataya
       Chief Executive Officer
       Western Magnesium Corp.
       900 - 580 Hornby Street
       Vancouver, BC, Canada, V6C 3B6

                                                        Re: Western Magnesium
Corp.
                                                            Registration
Statement on Form 10-12G
                                                            Filed October 12,
2021
                                                            File No. 000-56323

       Dear Mr. Ataya:

              We have reviewed your filing 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.

       Registration Statement on Form 10-12G filed October 12, 2021

       Regulation of Magnesium Production and Mining, Environmental Compliance,
page 6

   1.                                                   We note your disclosure
that you expected to have final local governmental approval of
                                                        your pilot magnesium
production facility in the third calendar quarter of 2021. Please
                                                        revise your disclosure
to indicate whether final approval has been received or provide an
                                                        update as to the status
of such approval.
       Risk Factors, page 7

   2.                                                   We note your disclosure
on page 38 that Ms. Evans serves as your chief financial officer
                                                        on a part-time basis.
Please include risk factor disclosure discussing the other business
                                                        activities of Ms. Evans
and the potential conflicts of interest that exist in relation to those
                                                        other activities, and
disclose the approximate number of hours that Ms. Evans will devote
                                                        to your business each
week.
 Sam Ataya
FirstName LastNameSam
Western Magnesium  Corp.Ataya
Comapany
October 27,NameWestern
            2021       Magnesium Corp.
October
Page 2 27, 2021 Page 2
FirstName LastName
Description of the Registrant's Securities to be Registered
Choice of Forum, page 67

3.       We note your revised disclosure in response to prior comment 6 and
reissue the comment
         in part. Please disclose whether the forum selection provision in your
bylaws applies to
         actions arising under the Securities Act or Exchange Act. In that
regard, we note that
         Section 27 of the Exchange Act creates exclusive federal jurisdiction
over all suits brought
         to enforce any duty or liability created by the Exchange Act or the
rules and regulations
         thereunder, and Section 22 of the Securities Act creates concurrent
jurisdiction for federal
         and state courts over all suits brought to enforce any duty or
liability created by the
         Securities Act or the rules and regulations thereunder. If the
provision applies to Securities
         Act claims, please also revise your prospectus to state that investors
cannot waive
         compliance with the federal securities laws and the rules and
regulations thereunder. If
         this provision does not apply to actions arising under the Securities
Act or Exchange Act,
         please also ensure that the choice of forum provision in your bylaws
states this clearly. In
         addition, please include risk factor disclosure regarding the
exclusive forum provision in
         your bylaws.
Financial Statements
Note 8 - Mineral Property Costs and Exploration and Evaluation Assets, page
F-46

4.       We note your response to prior comment eight, explaining that you have
not conducted
         impairment testing of assets associated with your mining claims
because you do not
         believe that current operating and cash flow losses coupled with a
history of operating and
         cash flow losses demonstrate continuing losses associated with the use
of these assets,
         although you are nevertheless of the view that the associated fair
values and undiscounted
         estimated future cash flows exceed the carrying values.

         If you have prepared cash flow projections based on the guidance in
FASB ASC 360-10-
         35-29 through 35-35, as mentioned in your response, these should be
considered in
         measuring the amount of impairment, or in determining that no
impairment has
         occurred, as prescribed by FASB ASC 360-10-35-17. However, such
projections would
         not obviate the need to conduct the prescribed testing, given that
your current and
         historical operating and cash flow losses are an example of
circumstances in FASB
         ASC 360-10-35-21(e), under which such testing is required.

         Please revise your disclosures on pages F-8 and F-38, which currently
express uncertainty
         about whether amounts capitalized for your exploration and evaluation
assets should be
         tested for impairment, to acknowledge the testing requirements based
on
         the circumstances referenced above.

         Given your disclosure on page three, stating that you have no plans to
extract minerals
         from any of your mining claims, also clarify the premise underlying
the projections that
         support your view on recoverability to understand whether these
correlate with FASB
 Sam Ataya
Western Magnesium Corp.
October 27, 2021
Page 3
       ASC 360-10-35-34, which pertains to assets that are not in use but under
development, or
       FASB ASC 360-10-35-48, which pertains to assets that will be abandoned.
Exhibits

5.     Please file the lease for your Burnaby, British Columbia Research and
Development Pilot
       Production Facility, the Real Estate Option Agreement with Harrison
County Community
       Improvement Corporation, your April 2021 and June 2021 Convertible
Debentures, and
       your agreement with Industrial Surplus Supplies Ltd. as exhibits to your
registration
       statement or tell us why you believe such agreements are not required to
be filed. See
       Item 601(b)(10) of Regulation S-K.
        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.

        You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Karl Hiller,
Accounting Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the
financial statements and related matters. Please contact Liz Packebusch, Staff
Attorney, at (202)
551-8749 or Karina Dorin, Staff Attorney, at (202) 551-3763 with any other
questions.



                                                            Sincerely,
FirstName LastNameSam Ataya
                                                            Division of
Corporation Finance
Comapany NameWestern Magnesium Corp.
                                                            Office of Energy &
Transportation
October 27, 2021 Page 3
cc:       Laura Anthony, Esq.
FirstName LastName