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                              August 23, 2021

       Aftandil Aibekov
       Chief Executive Officer
       Minerva Gold Inc.
       12/1 Kunayev str, IA 17
       Nur-Sultan, 010000, Kazakhstan

                                                        Re: Minerva Gold Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed August 9,
2021
                                                            File No. 333-255403

       Dear Mr. Aibekov:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our May
18, 2021 letter.

       Amendment No. 1 to Registration Statement on Form S-1 filed August 9,
2021

       Risk Factors, page 11

   1.                                                   We note your response
to prior comment 1, but are unable to locate the risk factor
                                                        discussing the risk of
doing business in Kazakhstan. Please revise to include a risk factor
                                                        addressing economic and
political risks related to doing business in Kazakhstan.

       Description of Business, page 21

   2.                                                   Please expand your
disclosure to discuss the material terms of your Option Agreement,
                                                        including the terms of
the option, the option period and consideration for the option. In
                                                        addition, please file
an executed copy of the Option Agreement.
 Aftandil Aibekov
Minerva Gold Inc.
August 23, 2021
Page 2
Interests of Named Experts and Counsel, page 33

3.    We note you have filed a legal opinion and related consent in response to
prior comment
      5. Please update your disclosure under the heading "Interests of Named
Experts and
      Counsel" to identify the counsel which has provided the opinion.
       You may contact Myra Moosariparambil, Staff Accountant, at (202)
551-3796 or Craig
Arakawa, Accounting Branch Chief, at (202) 551-3650 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 LastNameAftandil Aibekov
                                                           Division of
Corporation Finance
Comapany NameMinerva Gold Inc.
                                                           Office of Energy &
Transportation
August 23, 2021 Page 2
cc:       Roger D. Linn
FirstName LastName