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                                                                                                September 8, 2006

Mr. Aldo C. Zucaro
Chairman, Chief Executive Officer and President
Old Republic International Corporation
307 North Michigan Avenue
Chicago, Illinois 60601

Re:      Old Republic In ternational Corporation
 Form 10-K for fiscal year ended December 31, 2005
             File No. 001-10607

Dear Mr. Zucaro:

We have reviewed your July 7, 2006 re sponse to our May 25, 2006 letter and
have the following comments. In our comments, we ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may 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 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 fiscal year  ended December 31, 2005

Item 7 – Management Analysis of Financia l Condition and Results of Operations, page
23

1. Please refer to prior comment six. In your response you state that “management believes that using a 5% potential ra nge of reserve development provides a
reasonable benchmark for a sensitivity anal ysis of the Company's reserves as of
December 31, 2005.”  In disclosure-type format please clarify whether this
sensitivity analysis of +/- 5% is reas onably likely and provide an expanded
discussion of your basis for concluding that  it is reasonably likely that ultimate
loss development could develop unfavorab ly when you have released redundant
reserves in each year sin ce 1995.  If this sensitivity an alysis is not reasonably
likely, please provide a measure in disc losure-type format that represents a
reasonably likely outcome consistent w ith our interpretative guidance regarding

Mr. Aldo C. Zucaro
Old Republic International Corporation
September 8, 2006 Page 2
critical accounting estimates disclosure in Section V of Financial Reporting Release No. 72 issued on December 29, 2003.

Executive Summary

Cash, Invested Assets, and Shareholder's Equity, page 26

2. Please refer to prior comment seven.

• As it relates to the non-GAAP per sh are measures other than “cash and
invested assets,” you assert in your response that disclosure exists in
your filing explaining why these pe r share amounts provide useful
information to investors regarding your financial condition and results
of operations and the purposes for which management uses these non-GAAP measures.  However, we c ontinue to believe that your
disclosure does not appear to be responsive to Item 10(e) of
Regulation S-K.  Please remove these measures or provide us
expanded discussion in disclosure-type  format that explains why these
non-GAAP measures provide useful in formation to investors and the
purposes for which you use them.
• Regarding the per share amount of “cash and invested assets,” it is not
clear from your response how your presentation complies with Item
10(e) of Regulation S-K.  Per sh are amounts for “cash and invested
assets” appear to be a liquidity measure, which is prohibited by ASR
142. Also, refer to the Answer to Question 11 of our  “Frequently
Asked Questions Regarding Use of  Non-GAAP Financial Measure.”
Please remove this liquidity per share measure.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.   Your letter should key your responses to our comments.
Detailed letters greatly facil itate our review.  Please file  your letter on EDGAR under the
form type label CORRESP.

You may contact Frank Wyman, St aff Accountant, at 202-551-3660  or Don
Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

       S i n c e r e l y ,

       J i m  B .  R o s e n b e r g
      Senior Assistant Chief Accountant