SecProbe.io

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October 6, 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 September 8, 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  - Reserve for Loss and Loss Adjustment Expenses
----------------------------------------------------------

Comment 1 in the  Commission's  letter  refers to prior comment 6 in the May 25,
2006  comment  letter  and  requests  that Old  Republic  clarify  its  proposed
disclosures  regarding  the  "reasonably  likely"  expectation  of loss  reserve
development.  The final two  paragraphs of our July 7, 2006  response  under the
heading, "Volatility of Reserve Estimates and Sensitivity",  will be modified to
read as follows:

Volatility of Reserve Estimates and Sensitivity

Loss reserve  uncertainty  is  illustrated  by the  variability  in loss reserve
development  presented in the schedule  which  appears on page 9 under Item 1 of
this Annual Report on Form 10-K. That schedule shows the cumulative loss reserve
development  for each of the past ten years  through  December  31, 2005 for the
general insurance business which comprises the largest portion of Old Republic's
loss and loss  adjustment  expense  reserves at 82.5% of the total.  For each of
these ten calendar years, prior accident years' general insurance claim reserves
have  developed,  as a percentage of the original  estimates,  within a range of
5.8%  unfavorable in 2001 to a 7.2%  favorable  development in 1996. For the ten
year period the net development has averaged .6% favorable.

On a consolidated  basis,  over the  comparable  ten year period,  the favorable
prior year loss  reserve  development  has ranged from .9% to 12.9% and averaged
5.5%. Although management does not have a significant business reason for making
projections  of likely  outcomes of future loss  developments,  its analysis and
evaluation of Old  Republic's  existing  business mix,  current  aggregate  loss
reserve levels, and loss development patterns suggests the reasonable likelihood
that 2005 year-end loss reserves could ultimately  develop within a range of +/-
5%. The most significant factors impacting the potential reserve development for
each of the Company's  insurance  segments is discussed above. While the Company
has generally  experienced  favorable loss  development  for the latest ten year
period on an overall basis, the current analysis of loss development factors and
economic  conditions  influencing the Company's  insurance coverages indicates a
gradual  downward  trend in favorable  development  during the most recent three
years.  Consequently,  management  believes  that using a 5% potential  range of
reserve development  provides a reasonable  benchmark for a sensitivity analysis
of the Company's reserves as of December 31, 2005.

<PAGE>
Comment 2 - Executive Summary
-----------------------------
Cash, Invested Assets, and Shareholders' Equity, page 26
--------------------------------------------------------

The Commission's comment regarding the presentation of certain non-GAAP measures
on  page  24  of  the  Annual  Report  on  Form  10-K   indicates  that  further
clarification  is required  regarding  compliance  with Item 10(e) of Regulation
S-K.  We  propose to modify  the  disclosure  following  the  existing  table as
follows:

The table above presents consolidated results in terms of both operating and net
income to  highlight  the  effect of  investment  gain or loss  recognition  and
non-recurring items on period-to-period  comparisons.  Net operating income does
not replace  net income per share  computed in  accordance  with U.S.  GAAP as a
measure of  profitability.  The recognition of investment gains or losses can be
highly  discretionary  and  arbitrary  due to  such  factors  as the  timing  of
individual securities sales, recognition of losses from write-downs for impaired
securities,  tax-planning  considerations,  and changes in investment management
judgments  relative  to the  direction  of  securities  markets  or  the  future
prospects of individual investees or industry sectors.  Likewise,  non-recurring
items  such  as the  income  tax  recovery  described  above,  can  distort  the
comparability  of the  Company's  operating  performance  from period to period.
Accordingly, management uses the non-GAAP financial measures to further evaluate
current  operating  performance and believes the use of these measures  enhances
the  understanding  of Old Republic's  operations by highlighting the underlying
profitability of the business.

With respect to the table on page 26 of the Annual  Report on Form 10-K we agree
to remove  disclosure of the per share amounts for cash and invested  assets and
shareholders' equity, at cost from future filings.

                                              *****

We trust that the discussion above is responsive to the  Commission's  comments.
Please  feel free to contact me at (312)  762-4229  if you have any  comments or
questions.

Very truly yours,

/s/ Karl W. Mueller

Karl W. Mueller
Senior Vice President and Chief Financial Officer

cc:  A.C. Zucaro
     Chairman and Chief Executive Officer

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