SEC Comment Letter for OLD REPUBLIC INTERNATIONAL (ORI) — Dec 20, 2011

OLD REPUBLIC INTERNATIONAL CORP
Date: Dec. 20, 2011 · CIK: 0000074260 · Accession: 0000000000-11-072851

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AI Filing Summary & Sentiment

File numbers found in text: 001-10607

Date

December 20, 2011

Author

Joel Parker

Form

UPLOAD

Company

OLD REPUBLIC INTERNATIONAL CORP

Letter

December 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 completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely, /s/ Joel Parker
Joel Parker
A c c o u n t i n g B r a n c h C h i e f

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December 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 completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

 Sincerely,  /s/ Joel Parker

Joel Parker
        A c c o u n t i n g  B r a n c h  C h i e f

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