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 May 5, 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
 Response letter dated April 24, 2025
 File No. 001-12622
Dear Susan Kreh:

 We have reviewed your April 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 April 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. Based on your response our
understanding is
 that you consider several factors at your clay operations with respect
to the economic
 viability of your mineral reserves, including the amount of clay at the
mine
 location; projected costs related to operating the mine; demand for the
type or types
 of product the clay meets the specifications for; other geographic
factors such as
 proximity to permanent structures or bodies of water; and environment
factors and
 regulations.

 In order to meet the requirement of Item 1302(e)(4) of Regulation S-K, a
price for
 each commodity must be used that provides a reasonable basis for
establishing that
 the project is economically viable. This requirement can be satisfied by
quantifying
 May 5, 2025
Page 2

 the projected cost, or range of projected costs, that covers mining,
hauling, processing,
 and packaging.

 Please further expand subsequent disclosures to quantity projected cost,
or range of
 projected costs, in order to satisfy the price requirement under Item
1303(b)(3) of
 Regulation S-K.
 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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