SecProbe.io

October 20, 2011
 Via E-mail

Karl W. Mueller Senior Vice President      And Chief Financial Officer Old Republic International Corporation 307 North Michigan Avenue Chicago, Illinois 60601
Re:  Old Republic International Corporation
 Form 10-K for the Fiscal Year Ended December 31, 2010
Filed February 28, 2011 File No. 001-10607

Dear Mr. Mueller:
We have reviewed your September 20, 2011 response to our August 23, 2011 letter and
have the following comment.
 Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not believe the comment applies to your facts a nd circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your responses to our comment.
 After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.

Notes to Consolidated Financial Statements

Note 1 – Summary of Significant Accounting Policies
 (h) – Losses, Claims and Settlement Expenses, page 70

1. Refer to your responses to our comments three,  four and five. Refer to the table on page
70.  We acknowledge the Table you provided in  your response lette r that shows “the
estimated effects of coverage rescissions and claim denials on loss reserves and paid and
incurred losses.”  Please provide us proposed disclosure to be incl uded in future filings
that addresses the following:
 The table in your response letter contains a line item titled “Estimated rescission
reduction (increase) in losses incurred” of $178.3 million and $1,601.4 million for
years 2010 and 2009 respectively.  Quantify and di sclose the amount of this item that

Karl W. Mueller
Old Republic International Corporation October 20, 2011 Page 2

 is included in “Benefits, claims and sett lement expenses” on your Consolidated
Statements of Income for each year presen ted.  Further disclose what individual line
items these amounts impact on the table on page 70 of your Form 10-K and the amount included in each line item iden tified for all periods presented.

 The table in your response letter contains a line item titled “Estimated rescission
reduction in paid claims” of $748.8 mill ion and $719.5 million for years 2010 and
2009 respectively.  Quantify and disclose the amount of this  item that is included in
“Benefits, claims and settlement expenses” on your Consolidated Statements of Income for each year presented.

 To the extent that significant amounts are included in the line item “change in
provision for insured events of prior year s” on the  table on page 70, disclose the
reasons why your rescission estimates were  significantly overstated/understated and
discuss your assessment of the trend for years 2011 and beyond.

 Address how you considered your ongoing li tigation and arbitration proceedings
with, for example, Bank of America, Count rywide and Chase Bank in estimating your
rescission reduction reserve at December 31, 2010 and for future period estimates.
 Please contact James Peklenk, Staff Accountan t, at (202) 551-3661 or Lisa Vanjoske,
Assistant Chief Accountant, at (202) 551-3614 if you have an y questions regarding the
comments.  In this regard, do not hes itate to contact me at (202) 551-3651.

Sincerely,  /s/ Joel Parker  Joel Parker Accounting Branch Chief