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  Creating Value From Sorbent Minerals          February 24, 2025    VIA EDGAR  United States Securities and Exchange Commission  Division of Corporation Finance  100 F. Street, N.E.  Washington, D.C. 20549  Attn: Charles Eastman and Andrew Blume   Re: Oil-Dri Corporation of America  Form 10-K for the Fiscal Year Ended July 31, 2024  File No. 001-12622  Dear Messrs. Eastman and Blume:  This letter sets forth the responses of Oil-Dri Corporation of America (the "Company")  to the comment letter dated February 11, 2025 from the staff (the "Staff") of the Division of  Corporation Finance of the Securities and Exchange Commission (the "Commission") regarding  the Staff's review of the Company’s Form 10-K for the fiscal year ended July 31, 2024 filed on  October 10, 2024, File No. 001-12622 (the "Form 10-K").   For your convenience, the Staff's comments have been repeated below in their entirety,  with the Company's response to a particular comment set out immediately underneath it. The  headings and numbered paragraphs in this letter correspond to the headings and numbered  paragraphs in the comment letter from the Staff. Capitalized terms used but not defined in this  letter are intended to have the meanings ascribed to such terms in the Form 10-K.  Form 10-K for the Fiscal year Ended July 31, 2024  Item 2 Properties, page 28  1. Please revise your mineral reserve table to include the price, the selected point of  reference, for example in-situ, mill feed, saleable product, etc., and the grade/qualities as  required by Item 1303(b)(3) of Regulation S-K.  The Company acknowledges the Staff’s comment and respectfully proposes to revise its  disclosures as reflected in the illustrative disclosure below to include the selected point of  reference, in-situ, or in-place, as required by Item 1303(b)(3) of Regulation S-K, in future filings,  beginning with the Company’s annual report on Form 10-K for the fiscal year ending July 31,  2025.  The Company respectfully advises the Staff that the value of its clay is created through  the variety of mining, hauling, processing, and packaging methods, described in Item 2 –  Properties, Mining and Manufacturing Methods of our Form 10-K, that the Company uses to  produce each of its products. The clay itself does not have an inherent value, and therefore, the  Company does not attribute a price to its mineral reserves. As described in Item 1 - Business,

2    Principal Products of our Form 10-K, the Company’s clay is used to produce a variety of  products, often at the unique specifications of its customers. The Company’s products are made  using different grades/qualities of our clay, and while some clay may be acceptable for use in the  production of one product, it may not be fit for use in other products. There is no single size,  chemical, or physical specification that fits all customer requirements for the Company’s  products. Therefore, it is not practical or possible to include the price or the grades/qualities in  the mineral reserve table.   In its subsequent filings, the Company proposes revising its disclosure to include the  selected point of reference and to clarify its basis for not including the price or the  grades/qualities of its clay in the mineral reserve table. For example, in future filings, the  following disclosures would be revised as follows (new language underlined and in bold):  The first paragraph under “Summary of Mineral Resources and Mineral Reserves” on  Page 30 of the Form 10-K would be revised to read:  “We operate a number of mines concentrated near our production facilities in  California, Georgia, Illinois and Mississippi, although we have proven reserves in  other states. Based upon the quantitative and qualitative factors applicable, we do  not consider any of our mines to be individually material to our business or  financial condition. As a result, we are only required to disclose summary  information related to our mineral reserves. Our summary of mineral reserves as  of July 31, 2024, have been prepared and certified by a certified professional  geologist who qualifies as a "qualified person" as such term is defined in Item  1300 of Regulation S-K. The reference point for our mineral reserves is in- situ, or in-place, material. Item 1303 of Regulation S-K requires the disclosure  of mineral resources; however, we have no mineral resource estimates as all  mineral accumulations of economic interest and with reasonable prospects for  eventual economic extraction are either currently on production or subject to an  economically viable future development plan and are classified as mineral  reserves. Item 1303 of Regulation S-K also requires the disclosure of the  grades/qualities of our mineral reserves; however, because there is no single  size, chemical, or physical specification of our clay that fits all requirements  for our various products, it is not practical or possible for us to provide  information related to grades/qualities. Our summary of proven and probable  reserves as of July 31, 2024, is as follows:”  The paragraph immediately following the table on Page 30 of the Form 10-K would be  revised to read:  “Based on our rate of consumption during fiscal year 2024, and without regard to  any of our reserves in Nevada and Tennessee, where we do not actively mine, we  consider our proven and probable reserves adequate to supply our needs for over  forty years. Although we consider these reserves to be extremely valuable to our  business, because our clay has no inherent value and only becomes valuable  through the mining and manufacturing methods described below, it is not  practical or possible for us to provide information related to the price of our

3    mineral reserves.only a small portion of the reserves, those which were acquired  in acquisitions, are reflected at cost on our balance sheet.”    2. We note your disclosure on page 30 stating that you do not consider any of your mines to  be individually material. Please quantify the number of mines at each geographic location  and tell us if you have considered Item 1301(c)(3) of Regulation S-K in your individual  property materiality analysis.  The Company acknowledges the Staff’s comment and advises that it has a total of 70  mines located in the following geographic locations:    Geographic Location Number of Mines  California 3  Georgia 38  Illinois 3  Mississippi 24  Nevada 1  Tennessee 1     In its subsequent filings, the Company advises the Staff that it will revise its disclosure to  include the number of mines at each geographic location. For example, in future filings, the first  paragraph under the table provided under “Clay Resources and Reserves” on Page 29 of the  Form 10-K would be revised as follows (new language underlined and in bold):  “With the exception of our research and development center in Illinois, all of the  properties that we own contain clay mineral reserves or are used in the processing  of our clay. We mine sorbent minerals primarily consisting of calcium bentonite,  attapulgite and diatomaceous shale which we refer to in the aggregate as “clay,”  “minerals,” or “Fuller’s Earth.” We use certified professional geologists and  mineral specialists who prepared the estimated reserves of these minerals in the  table above. See also Item 1 “Business” above for further information about our  reserves. We, or our wholly owned subsidiaries, are the sole operators of our  mines. We have a total of 70 mining active properties in all stages of operation  (exploration, development and production), with 3 mines in California, 38  mines in Georgia, 3 mines in Illinois, 24 mines in Mississippi, 1 mine in  Nevada, and 1 mine in Tennessee. Our properties in production, located in  Mississippi, Georgia, California and Illinois, collectively produced approximately  793 thousand and 807 thousand tons of finished product in fiscal years 2024, and  2023, respectively. Parcels of such land are also sites of manufacturing facilities  operated by us. In addition, we own approximately one acre of land in Laval,  Quebec, Canada, which is the site of the processing, packaging and distribution

4    facility for our Canadian subsidiary. While we have reserves at our mining  properties in Nevada and Tennessee, we are not actively mining these  properties.”       The Company considers Item 1301(c)(3) of Regulation S-K in its individual property  materiality analysis and considers, for each property, as applicable, all related activities from  exploration through extraction to the first point of material external sale, including processing,  transportation, and warehousing. Based on the quantitative and qualitative factors applicable to  each mine, including but not limited to, the size of and current or planned activity at each mine,  the Company does not consider any of our mines to be individually material to its business or  financial condition.    Management's Discussion and Analysis of Financial Condition and Operations Results of  Operations, page 34  3. When more than one factor is responsible for the change in a statement of operations  line item between periods, please clearly quantify each of the contributing factors,  including any offsetting amounts. For example, you disclose that your domestic cost of  goods sold per ton increased 6%, driven primarily by increases in non-fuel manufacturing  and freight and offset by lower natural gas and packaging costs. When you discuss net sales  fluctuations, specifically describe the extent to which changes are attributable to changes in  prices or to changes in the volume or amount of goods or services being sold or to the  introduction of new products or services. Refer to Item 303(b)(2) of Regulation S-K and  SEC Release No. 33-8350.  The Company acknowledges the Staff’s comment and respectfully confirms that, in  future filings, beginning with the Company’s quarterly report on Form 10-Q to be filed for the  quarter ended January 31, 2024, it will enhance the disclosure to clearly quantify each of the  contributing factors, including any offsetting amounts, when more than one factor is responsible  for any disclosed material change in a statement of operations line item between periods to the  extent that such information is quantifiable and necessary for an understanding of the Company’s  results.     Critical Accounting Policies and Estimates, page 38  4. Please enhance your disclosure in future filings to provide qualitative and quantitative  information necessary to understand the estimation uncertainty and the impact your  critical accounting estimates have had or are reasonably likely to have on your financial  condition and results of operations. In doing so, discuss how much each estimate and/or  assumption has changed over a relevant period and the sensitivity of reported amounts to  the underlying methods, assumptions and estimates used. The disclosures should  supplement, not duplicate, the description of accounting policies or other disclosures in the  notes to the financial statements. Refer to Item 303(b)(3) of Regulation S-K and SEC  Release No. 33-8350.

5     The Company acknowledges the Staff’s comment and respectfully confirms that, in  future filings, beginning with the Company’s annual report on Form 10-K to be filed for the  fiscal year ending July 31, 2025, it will enhance its disclosure to provide qualitative and  quantitative information necessary to understand the estimation uncertainty and the impact our  critical accounting estimates have had or are reasonably likely to have on the Company’s  financial condition and results of operations, to the extent such information is material and  reasonably available. The Company will also disclose any changes in estimates and/or  assumptions over the relevant period and the sensitivity of reported amounts to the underlying  methods, assumptions, and estimates used over the relevant period, to the extent such  information is material and reasonably available.    Notes to the Consolidated Financial Statements  Note 1 - Summary of Significant Accounting Policies  Intangibles and Goodwill, page 50  5. We note that you allocated $20.4 million of the Ultra Pet acquisition consideration to a  customer list intangible asset which you amortize on a straight-line basis over 18 years.  Please confirm whether or not this asset pertains solely to a customer list as the term is  described in ASC 805-20-55-21. Tell us in sufficient detail how you determined the useful  life of the customer list and how you considered ASC 350-30-35-3 in arriving at this  determination. Also clarify how you determined it was appropriate to amortize the  customer list on a straight-line basis, as opposed to an accelerated method, and how this  reflects the pattern in which you realize the economic benefits of the customer list. Refer to  ASC 350-30-35-6 and ASC 350-30-55-2 through 4.   The Company acknowledges the Staff’s comment and respectfully confirms that this  asset pertains solely to a customer list as the term is described in ASC 805-20-55-21.   The Company respectfully advises the Staff that it determined a useful life of 18 years  was appropriate for the customer list primarily based upon (i) historical customer attrition rates;  (ii) management’s review of the present value of excess earnings expected to be generated in the  future from the customer list and determination that nearly all of the total excess value  attributable to customer list was earned within 18 years; and (iii) discussions with a third-party  valuation firm we engaged to perform a fair value assessment of the Ultra Pet acquisition, who  recommended a useful life of less than 20 years.   The Company considered each of the applicable factors outlined in ASC 350-30-35-3  when determining useful life, particularly the expected use of the asset, historical experience, and  the effects of obsolescence, demand, competition, and other economic factors. The Company  expected to continue using the customer list to generate revenue through the sale of Ultra Pet  products. The Company’s management team has extensive experience managing relationships  with customers in the cat litter business, regardless of whether those arrangements have explicit  renewal or extension provisions. The Company utilized that experience while assessing the  reasonableness of useful life of the customer list. This experience guided the Company’s use of  historical customer attrition rates and its review of the present value of excess earnings expected  to be generated in the future from the customer list, as well as an understanding of the value of

6    Ultra Pet’s customer base being primarily comprised of long-term business partners. While  competition exists, demand for crystal cat litter has grown over recent years, and the Company  does not foresee instability in the cat litter industry or crystal litter segment having an impact on  the useful life of the customer list.   The Company respectfully advises the Staff that it determined it was appropriate to  amortize the customer list on a straight-line basis because it expects the economic benefits from  Ultra Pet’s customer relationships to be spread evenly across the useful life of the asset. ASC  350-30-35-6 provides that the method of amortization shall reflect the pattern in which the  economic benefits of the intangible asset are consumed or otherwise used up. Ultra Pet has  longstanding relationships with its customers, as indicated by its historically low customer  attrition rate. Additionally, the sales history did not indicate that revenues would be spread  unevenly throughout the customer list’s useful life. There is no indication that revenues  generated by the customer list will be higher in the earlier stages of its useful life, and so the  Company deemed that an accelerated method was not appropriate. A