SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   March 31, 2008   Spencer LeRoy III, Esquire Senior Vice President, Gene ral Counsel and Secretary
Old Republic International Corporation 307 North Michigan Avenue Chicago, Illinois 60601-5382
Re: Old Republic International Corporation
 Form 10-K for the Year Ended December 31, 2007  Filed February 26, 2008  File No. 001-10607

Dear Mr. LeRoy:

We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with  information to better understand your
disclosure. Where it requests you to revise disclosure, the information you provide should
show us what the revised di sclosure will look like and iden tify the annual or quarterly
filing, as applicable, in which you intend to first include it. If you do not believe that
revised disclosure is necessary, explain the r eason in your response.  After reviewing the
information provided, we may raise additional comments and/or request that you amend your filing.     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, filed 2/26/08

Risk Factors Common to A ll Subsidiaries, page 17

Financial Institutions Risk, page 18

1. To the extent material, please (a) revise your disclosure in this risk factor to name
the financial institutions which you have a concentrated risk of financial exposure
and quantify the risk involved and (b) revise the section “Item 7A. Quantitative

Spencer LeRoy III, Esquire
Old Republic International Corporation
March 31, 2008 Page 2
and Qualitative Disclosure  About Market Risk” on page 47 to provide the
information required by Item 305(b) of Regulation S-K in connection with this market risk exposure.
 Item 15. Exhibits and Financial Statement Schedules

 Signatures

 2. It appears that your Form 10-K has not been signed by your controller or principal accounting officer pursuant to Instruction D to Form 10-K.  If Karl Mueller, your
chief financial officer, is also your controller or principal accounting officer you should indicate beneath his signature that  he is signing in the capacity of chief
financial officer and controller or principal accounting officer.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter that keys your responses to
our comments and provide any requested information.  Detailed letter s greatly facilitate
our review.  Please file y our letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.

Spencer LeRoy III, Esquire
Old Republic International Corporation March 31, 2008 Page 3
 Please contact Jennifer Riegel, Staff A ttorney at (202) 551-3575, Suzanne Hayes,
Branch Chief at (202) 551-3675 or me at (202) 551-3715 with any questions.

Sincerely,

Jeffrey Riedler
       A s s i s t a n t  D i r e c t o r