SecProbe.io

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July 7, 2006

Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Mail Stop 03-09
Washington, DC 20549

Re: Old Republic International Corporation
    Form 10-K, fiscal year ended December 31, 2005
    File No. 001-10607

Dear Mr. Rosenberg,

We have  reviewed  the  comments on our above  referenced  filing in your letter
dated May 25, 2006. Old Republic's  response to the Commission's  comments is as
follows:

Item 7 - Management analysis of Financial Condition and Results of Operations,
         ---------------------------------------------------------------------
         page 23
         -------

Comment 1 - Critical Accounting Estimates
-----------------------------------------

We are aware of the requirements of Section V of Financial Reporting Release No.
72 that  requires  disclosure in Management  Discussion  and Analysis  (MD&A) of
material  uncertainties  associated with the methods,  assumptions and estimates
underlying the Company's critical accounting measurements.  We have historically
taken the  approach of  embedding  the  discussion  of our  critical  accounting
estimates  within the  corresponding  section of MD&A rather than  presenting  a
separate discussion. However, in an effort to enhance the disclosure we agree to
prospectively  modify  our MD&A to  include a  separate  discussion  immediately
following the "Executive Summary".

Critical  Accounting  Estimates

The Company's annual and interim financial statements incorporate a large number
and types of  estimates  relative to matters  which are highly  uncertain at the
time the estimates are made.  The  estimation  process  required of an insurance
enterprise is by its very nature highly  dynamic  inasmuch as it  necessitates a
continual process of evaluating,  analyzing,  and quantifying factual data as it
becomes  known to the  Company.  As a result,  actual  experienced  outcomes can
differ from the  estimates  made at any point in time,  and thus  affect  future
periods' reported revenues, expenses, net income, and financial condition.

Old Republic believes that its most critical accounting  estimates relate to: a)
the  determination  of  other-than-temporary  impairments  in the value of fixed
maturity and equity  investments;  b) the establishment of deferred  acquisition
costs which vary directly  with the  production  of insurance  premiums;  c) the
recoverability of reinsured paid and/or outstanding  losses; and d) the reserves
for losses and loss adjustment expenses.  The major assumptions and methods used
in the establishment of these estimates are discussed in the pertinent  sections
of this Management Analysis and are summarized as follows:

<PAGE>
a) Other-than-temporary impairments in the value of investments:

Individual securities are considered for a possible write-down:

   * In the event their  market value has dropped by 20% or more below their par
     or  amortized  cost  and/or the  security  has been in an  unrealized  loss
     position for twelve consecutive months;

   * In the event of issuer default on  significant  obligations or emergence of
     such  adverse  information  as to  bring  into  question  the  validity  of
     previously reported earnings or financial condition; and

   * When  the  probability  of  non-recovery  of  the  original  investment  is
     established, the foregoing events or occurrences notwithstanding.

For  the  three  years  ended   December  31,  2005,   pretax   charges  due  to
other-than-temporary  impairments  in  the  value of  securities reduced  pretax
income within a range of 2.4% and 0.8% and averaged 1.5% of such income.

b) Establishment of deferred acquisition Costs ("DAC")

The  eligibility  for  deferral  and the  recoverability  of DAC is based on the
current terms and recent  profitability of the insurance contracts to which they
relate. As of the three most recent year ends,  consolidated DAC balances ranged
between  2.3% and 2.1% and  averaged  2.2% of  consolidated  assets.  The annual
change  in  DAC  balances  for  the  three-year  period  reduced   underwriting,
acquisition  and other  expenses  within a range of 1.6% and 0.5%,  and averaged
0.9% of such expenses.

c) The recoverability of reinsured paid and/or outstanding losses

Assets consisting of gross paid losses recoverable from assuming reinsurers, and
balance sheet date reserves  similarly  recoverable  in future  periods as gross
losses are settled and paid are established at the same time as the gross losses
are paid or recorded as reserves.  Accordingly,  these assets are subject to the
same  estimation  processes  and  valuations  as the  related  gross  amounts as
discussed  below.  As of the three most recent year ends,  paid and  outstanding
reinsurance  recoverable  balances  ranged  between 39.7% and 38.4% and averaged
39.1% of the related gross reserves.

d) The reserves for losses and loss adjustment expenses

As discussed in pertinent sections of this Management Analysis, the reserves for
losses and  related  loss  adjustment  expenses  are based on a wide  variety of
factors and  calculations.  Among these the Company  believes the most  critical
are:

   * The  establishment  of expected  loss ratios for the three latest  accident
     years,   particularly  for  so-called  long  tail  coverages  as  to  which
     information  about  covered  losses  emerges  and becomes  more  accurately
     quantified over long periods of time. Long tail lines of business generally
     include workers compensation, auto liability, general liability, errors and
     omissions and directors and officers' liability, and title insurance. Gross
     loss reserves  related to such long tail coverages ranged between 86.1% and
     83.8%,  and averaged 84.7% of gross  consolidated  claim reserves as of the
     three most recent year ends. Net of reinsurance recoverables, such reserves
     ranged between 83.3% and 82.1% and averaged 82.6% as of the same dates.

   * Loss trend factors that are used to establish the above noted expected loss
     ratios.  Such factors take into  account  such  variables as judgments  and
     estimates  for premium  rate  trends and  adequacy,  current  and  expected
     interest rates,  current and expected social and economic inflation trends,
     and insurance industry statistical claim trends.

   * Loss development  factors based on Company and/or industry  statistics that
     are used to project  reported  losses for each  accounting  period to their
     estimated ultimate cost.

                                       2

<PAGE>

For  each of the  three  most  recent  calendar  years,  prior  accident  years'
consolidated claim costs have developed  favorably and consequently have had the
effect of reducing  consolidated  annual loss costs between 2.9% and 5.2%, or by
an average of  approximately  3.8% per annum.  As a percentage  of each of these
years'  consolidated  earned premiums and fees the favorable  developments  have
ranged between 1.3% and 2.1%, and have averaged 1.6%.

In all the above regards the Company  anticipates that future periods' financial
statements  will continue to reflect  changes in estimates.  As in the past such
changes will result from altered circumstances,  the continuum of newly emerging
information  and its effect on past  assumptions  and judgments,  the effects of
securities markets valuations,  as well as changes in inflation rates and future
economic  conditions  beyond the Company's  control.  As a result,  Old Republic
cannot predict, quantify, or guaranty the likely impact that probable changes in
estimates will have on its future financial condition or results of operations.

Comments 2 through 6 and 9 - Reserve for Loss and Loss Adjustment Expenses
--------------------------------------------------------------------------

Comments  2  through  6  and 9 in  the  Commission's  letter  suggest  that  Old
Republic's  disclosures  could be  improved in regard to the  estimation  of the
reserve  for  loss and loss  adjustment  expenses,  the  methodology  used,  key
assumptions  impacting the estimates,  and the  variability in reported  results
stemming  from  "reasonably  likely"  changes  to  one  or  more  of  these  key
assumptions.

In response,  we wish to note that Old Republic's periodic estimates of loss and
loss adjustment  expense reserves emanate from a significant  number of analyses
performed by operating  management  and accounting  professionals.  Old Republic
does not utilize either internal or external actuaries in the reserve estimation
process.  Internal  actuaries are used primarily in the rate setting process and
periodically  evaluate the reasonableness of management's  reserve estimates for
certain accounts or blocks of business on an as needed basis. External actuaries
are  engaged  by the  Company  to perform  an annual  evaluation  of  individual
insurance  subsidiary  statutory carried reserves as of each balance sheet date.
As a result of their work, the external  actuaries render an annual statement of
actuarial opinion for each insurance company. Such opinions are submitted to the
insurance department in the respective  companies' state of domicile.  There are
no significant differences between loss and loss adjustment expense reserves for
statutory and GAAP reporting purposes. Management does consider on a prospective
basis the results  from the  periodic  actuarial  evaluations  in the context of
other trends and analysis available to it when making its recurring judgments on
the reasonableness of the carried loss reserves at any reporting date.

The  proposed  disclosures  noted  below  are  provided  in the  context  of the
Company's  loss  reserve  estimation  process and the  limitations  it places on
management's  ability to quantify the impact of "reasonably  likely"  changes in
key assumptions and future reported  results.  In order to clarify the Company's
disclosures in this area we propose to replace the disclosure  beginning on page
35 in the 2005 Annual Report on Form 10-K under the heading "Expenses:  Benefits
and Claims", with the following disclosure on a prospective basis:

Reserves for Loss and Loss Adjustment Expenses

In order to  achieve a  necessary  matching  of  premium  and fee  revenues  and
expenses, the Company records the benefits,  claims and related settlement costs
that have been incurred  during each  accounting  period.  Total claim costs are
affected  by the amount of paid  claims and the  adequacy  of reserve  estimates
established for current and prior years' claim occurrences at each balance sheet
date.

                                       3

<PAGE>

The  following  table shows a breakdown  of gross and net of  reinsurance  claim
reserve estimates for major types of insurance coverages as of December 31, 2005
and 2004:
<TABLE>
                                                                                       December 31,
                                                                    -------------------------------------------------
                                                                              2005                      2004
                                                                    ------------------------   -----------------------
                                                                      Gross          Net         Gross          Net
                                                                    ----------    ----------   ----------    ---------
<s>                                                                 <c>          <c>          <c>           <c>
Claim and Loss Adjustment Expense Reserves:
Commercial automobile (mostly trucking)......................       $    878.4    $    692.9   $    788.6    $   635.9
Workers' compensation........................................          1,775.0         915.1      1,607.0        814.0
General liability............................................            991.3         418.1        808.7        350.5
Other coverages..............................................            597.5         387.8        576.0        382.1
Unallocated loss adjustment expense reserves.................            159.2          92.9        122.0         87.2
                                                                    ----------    ----------   ----------    ---------
      Total general insurance reserves.......................          4,401.7       2,507.0      3,902.4      2,269.7

Mortgage guaranty............................................            214.7         213.7        200.5        199.1
Title........................................................            268.8         268.8        252.5        252.5
Life and health..............................................             26.5          19.9         22.6         16.9
Unallocated loss adjustment expense reserves -
   other coverages...........................................             28.0          28.0         25.4         25.4
                                                                    ----------    ----------   ----------    ---------
      Total claim and loss adjustment expense reserves.......       $  4,939.8    $  3,037.6   $  4,403.5    $ 2,763.8
                                                                    ==========    ==========   ==========    =========
Asbestosis and environmental claim reserves included
 in the above general insurance reserves:
       Amount................................................       $    170.7    $    132.2   $    118.9    $    97.1
                                                                    ==========    ==========   ==========    =========
       % of total general insurance reserves.................             3.9%          5.3%         3.0%         4.3%
                                                                    ==========    ==========   ==========    =========
</TABLE>

The  Company's  reserve for loss and loss  adjustment  expenses  represents  the
accumulation  of  estimates  of  ultimate  losses,  including  incurred  but not
reported  losses  and  loss  adjustment  expenses.  The  establishment  of claim
reserves by the Company's  insurance  subsidiaries  is a reasonably  complex and
dynamic  process  influenced by a large variety of factors as further  discussed
below. Consequently,  reserves established are a reflection of the opinions of a
large number of persons,  of the  application and  interpretation  of historical
precedent  and  trends,  of  expectations  as to  future  developments,  and  of
management's judgment in interpreting all such factors. At any point in time the
Company is exposed to possibly higher or lower than anticipated  claim costs and
the  resulting  changes in estimates  are recorded in  operations of the periods
during  which they are made.  Increases  to prior  reserve  estimates  are often
referred  to as  unfavorable  development  whereas  any  changes  that  decrease
previous  estimates  of the  Company's  ultimate  liability  are  referred to as
favorable development.

Overview of Loss Reserving Process

Most of Old Republic's consolidated claim and related expense reserves stem from
its general insurance  business.  At December 31, 2005, such reserves  accounted
for 89.1%  and 82.5% of  consolidated  gross  and net of  reinsurance  reserves,
respectively,  while similar reserves at December 31, 2004 represented 88.6% and
82.1% of the respective consolidated amounts.

The  Company's  reserve  setting  process  reflects the nature of its  insurance
business and the decentralized basis upon which it is conducted.  Old Republic's
general  insurance  operations  encompass a large variety of lines or classes of
commercial  insurance;  it has  negl