SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   April 15, 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 filed February 26, 2008  Form 10-K/A filed March 31, 2008  File No. 001-10607

Dear Mr. LeRoy:

We have reviewed your filings and have the following comments.  Where
indicated, we think you should revise your Form  10-K/A in response to these comments.
If you disagree, we will consider your e xplanation as to why our comments are
inapplicable or a revision is unnecessary.  Af ter 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 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/A, filed March 31, 2008

 1. We note that this Form 10-K/A was not signed on behalf of the company by a
duly authorized representative of the co mpany.  See Rule 12b-15 of the Securities
and Exchange Act and Rule 302(a) of Regul ation S-T.  Please amend this filing
accordingly.

*    *    *    *

Spencer LeRoy III, Esquire
Old Republic International Corporation April 15, 2008 Page 2
 Please amend your Form 10-K/A and respond to these comments within 10
business days or tell us when you will provide us with a response.  Please furnish a cover
letter with your amendment that keys your  responses to our comments and provide any
requested information.  Detailed letters greatl y facilitate our review .  Please file your
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.
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