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                          October 3, 2023

       Karl Hanneman
       Chief Executive Officer
       International Tower Hill Mines Ltd.
       2710-200 Granville Street
       Vancouver, BC, V6C 1S4
       Canada

                                                        Re: International Tower 
Hill Mines Ltd.
                                                            Form 10-K for the 
Fiscal Year ended December 31, 2022
                                                            Filed March 8, 2023
                                                            File No. 001-33638

       Dear Karl Hanneman:

               We issued comments to you on the above captioned filing on 
August 3, 2023. As of the
       date of this letter, these comments remain outstanding and unresolved. 
We expect you to provide
       a complete, substantive response to these comments by October 18, 2023.

               If you do not respond, we will, consistent with our obligations 
under the federal securities
       laws, decide how we will seek to resolve material outstanding comments 
and complete our
       review of your filing and your disclosure. Among other things, we may 
decide to release
       publicly, through the agency's EDGAR system, all correspondence, 
including this letter, relating
       to the review of your filings, consistent with the staff's decision to 
publicly release comment and
       response letters relating to disclosure filings it has reviewed.

                                                        You may contact Karl 
Hiller, Branch Chief, at 202-551-3686 with any questions.



                                                                                
                          Sincerely,

                                                                                
                          Division of Corporation Finance
                                                                                
                          Office of Energy & Transportation