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 April 11, 2025

Susan Kreh
Chief Financial Officer
Oil-Dri Corporation of America
410 North Michigan Avenue , Suite 400
Chicago , Illinois 60611

 Re: Oil-Dri Corporation of America
 Form 10-K for the Fiscal year Ended July 31, 2024
 File No. 001-12622
Dear Susan Kreh:

 We have reviewed your February 24, 2025 response to our comment letter
and have
the following comment.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our February
11, 2025 letter.

Form 10-K for the Fiscal year Ended July 31, 2024
Item 2. Properties, page 28

1. We note your response to comment 1. Please provide us with additional
information
 related to the price and quality disclosure requirements found under
Item 1303(b)(3)
 of Regulation S-K.

 Please tell us how you assess the economic viability of the materials
designated as
 mineral reserves. For example, tell us if their is a minimum price
considered at each
 mine that covers mining, hauling, processing, and packaging in order to
establish the
 economic viability of the material mined; or another method that you use
to establish
 the economic viability of your mineral reserves.

 Additionally, please tell us how you distinguish ore from waste at your
mining
 operations. For example, is there a minimum quality threshold, chemical
 April 11, 2025
Page 2

 specification, or other method that you use to separate ore from waste
at each mine.
 Please contact Charles Eastman at 202-551-3794 or Andrew Blume at
202-551-3254
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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