CLIFFORD L. NEUMAN, P.C.
Attorney at Law
TEMPLE-BOWRONHOUSE
1507 PINESTREET
BOULDER,COLORADO80302
Telephone: (303) 449-2100
Facsimile: (303) 449-1045
E-mail: clneuman@neuman.com
July 24, 2014
Tia L. Jenkins, Senior Assistant Chief Accountant
United States Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
| Re: | Athena Silver Corporation |
|
| Form 10-K for the Year Ended December 31, 2013 |
|
| Filed March 28, 2014 Form 10Q for the Quarter Ended March 31, 2014 Filed May 8, 2014 |
|
| File No. 000-51808 |
Dear Ms. Jenkins:
On behalf of Athena Silver Corporation (the "Company") please accept the following in response to the comments of the Commission dated July 17, 2014. The revisions to the subject reports are located within our Form 10-K/A-1 and Form 10Q/A-1 filed concurrently herewith.
Comment No. 1:
Revised as requested.
Comment No. 2:
Revised as requested.
Comment No. 3:
Revised as requested.
Comment No. 4:
Revised as requested.
The Company hereby acknowledges that:
·
it is responsible for the adequacy and accuracy of the disclosures in this 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
·
it 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.
Tia L. Jenkins
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
July 24, 2014
Page 2
Please let me know if you have further comments or questions.
| Sincerely, |
| CLIFFORD L. NEUMAN, PC |
| /s/ Clifford L. Neuman |
| Clifford L. Neuman |