SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 6010

         April 20, 2009

Karl W. Mueller
President, Chief Financial Officer, and
Principal Accounting Officer
307 North Michigan Avenue
Chicago, IL 60601

Re:   Old Republic International Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2008
 Filed February 27, 2009
 File Number:  001-10607

Dear Mr. Mueller:

We have limited our review of your filing to those issues we have addressed in
our comments.  In our comments, we ask you to  provide us with information to better
understand your disclosure.  Where our commen t requests you to revi se disclosure, the
information you provide should show us what the revised disclosure will look like and
identify the annual or quarterly filing, as a pplicable, in which you in tend to first include
it.  If you do not believe that revised disclo sure is necessary, expl ain the reason in your
response.  After reviewing the informati on 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.

Notes to Consolidated Financial Statements
Note 1:  Summary of Significant Accounting Policies
(h) Losses, Claims and Settlement Expenses, page 60

1. Regarding your policy for establishing a lo ss reserve for your mortgage guaranty line
of business:
• Revise to clarify, if true, that a reserve is established only upon default;
• Define in your disclosure what default means; and
• Disclose the dollar amount of the reserv e that represents IBNR at each balance
sheet date presented.

Karl W. Mueller
Old Republic International Corporation April 20, 2009 Page 2
2. For each line item under “incurred claims and claim adjustment expenses” and
“payments” in the table showing an analysis  of changes in aggregate reserves, please
disclose for each period presented the am ount attributable to each major business
segment (i.e. General, Mortgage Guaranty and Title).

* * * *
 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish 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 a ny 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 pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement 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 comments on your filing.

You may contact Dana Ha rtz, Staff Accountant, at (202) 551-3648 or Don
Abbott, Review Accountant, at (202) 551-3608 if you have any questions regarding the
comment.  In this regard, do not hesi tate 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