SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010
April 2, 2009
 Mr. Andrew N. Peterson Vice President and CFO Oil-Dri Corporation of America 410 North Michigan Avenue, Suite 400 Chicago, IL  60611-4213
 RE: Form 10-K for the fiscal  year ended July 31, 2008
Form 10-Qs for the periods ended October 31, 2008 and January 31,
2009
  Schedule 14A filed October 31, 2008
  File No. 1-12622

Dear Mr. Peterson:
We have reviewed your response lett er dated March 27, 2009 and have the
following additional comments.  If you disagree with a comment, we will consider your explanation as to why our comment is inappl icable or a revision is unnecessary.  Please
be as detailed as necessary in your explanat ion.  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 or  may not raise additional comments.
  Please understand that the purpose of our re view 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 on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

FORM 10-K FOR THE YEAR ENDED JULY 31, 2008

 General

1. Where a comment below requests additional disclosures or other revisions to be made, please show us in your supplemental response what the revisions will look like.  These revisions should be included in your future filings.

Mr. Andrew N. Peterson
Oil-Dri Corporation of America April 2, 2009 Page 2 of 2   Item 8 – Financial Statements and Supplementary Data, page 37

 Item 3 – Operating Segments, page 48

2. We have reviewed your response to prior comment 15 and have the following additional comments:
• Your proposed disclosure states “the  corporate expenses line includes
primarily certain unallocated expenses including administrative costs, research
and development costs and other non- operating expenses.”  Please enhance
your disclosure to provide examples of the types of items included in other
non-operating expenses.
• We previously requested that you discuss in your segment MD&A the
business reasons for the changes between  periods in the co rporate expenses
line item.  We note your response that  changes in items included within
corporate expenses are presented within your selling, general and
administrative expenses discussion in your MD&A.  Since items included in
the corporate expenses line item repr esent only a portion of your selling,
general and administrative expenses, we believe it is important to separately discuss in your segment MD&A the bus iness reasons for the changes between
periods in the corporate expenses line  item.  Please revise accordingly.

*    *    *    *
 Please respond to these comments within  10 business days, or tell us when you
will provide us with a response.  Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review.  Please file your supplemental response on EDGAR as a correspondence file.  Please understand that we may have additional comments after reviewing your responses to our comments.
You may contact Dietrich King, Staff Attorney, at (202) 551-3338 if you have
any questions regarding legal or disclosure matters.  Please contact Jeffrey Gordon, Staff
Accountant, at (202) 551-3866 or, in his absence, the unde rsigned at (202) 551-3769 if
you have questions regarding comments on the fi nancial statements and related matters.

 Sincerely,
   Rufus Decker
 Accounting Branch Chief