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May 22, 2024
William Heissenbuttel
President and Chief Executive Officer
Royal Gold, Inc.
1144 15th Street, Suite 2500
Denver, CO 80202
Re:Royal Gold, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Form 10-K/A for the Fiscal Year Ended December 31, 2023
Response dated May 14, 2024
File No. 001-13357
Dear William Heissenbuttel:
            We have reviewed your May 14, 2024 response to our comment letter and have the
following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our April 9, 2024 letter.
Form 10-K/A for the Fiscal Year Ended December 31, 2023
Item 2. Properties, page 4
1.We note your response to comment 1 and we reissue the comment. After considering your
response we continue to believe that the accommodations under Item 1303(a)(3) and
1304(a)(2) of Regulation S-K for royalty and streaming companies permit the omission of
information, including mineral resources and mineral reserves, however the
accommodations do not permit the substitution of mineral resources and mineral reserve
prepared under other mineral reporting regimes. Please revise to remove resources and
reserves from your filing that are not S-K 1300 compliant.
2.Additionally please provide additional context with respect to your ability to prepare a
technical report summary for a material property. For example, in response to comment 1,
you maintain that royalty and streaming companies typically do not have access to mining

 FirstName LastNameWilliam Heissenbuttel
 Comapany NameRoyal Gold, Inc.
 May 22, 2024 Page 2
 FirstName LastName
William Heissenbuttel
Royal Gold, Inc.
May 22, 2024
Page 2
properties and cannot produce their own S-K 1300 compliant mineral resource and
mineral reserve estimates. However, Exhibit 10.47 to your Form 10-K for the Fiscal Year
Ended June 30, 2019 filed August 8, 2019 includes language on page 31 that appears to
permit access to the property for the purpose of preparing a technical report.

The language states, "Upon no less than ten Business Days’ notice to the Seller, and
subject at all times to the workplace rules and supervision of the Owner, and provided any
rights of access do not interfere with any exploration, development, mining or processing
work conducted at the Project, the Seller shall grant, or cause to be granted, to the
Purchaser and its representatives and agents, at mutually agreeable times during normal
business hours and at the Purchaser’s sole risk and expense, the right to access the Project
to monitor the Seller’s compliance with the terms and conditions of this Agreement, to
receive information reasonably required to assist the Purchaser’s general understanding of
the operations of the Project and to prepare on behalf of the Purchaser or any of its
Affiliates any technical report in accordance with NI 43-101 and as otherwise required by
Applicable Laws. The Purchaser shall be responsible for injuries to, or damages suffered
by, the Purchaser and its representatives or agents while visiting the Project unless such
injuries and damages are caused by the negligence or willful misconduct of a Seller Group
Entity or its Affiliates or representatives."

In your response please tell us if your other agreements for material properties have
similar terms.
3.We note your response to comment 2. Please provide a draft of your proposed future
disclosure.
            Please contact Jennifer Monick at 202-551-3295 if you have questions regarding
comments on the financial statements and related matters. If you have questions regarding
comments on mining operations, please contact John Coleman at 202-551-3610 or Craig
Arakawa at 202-551-3650.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction