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 March 28, 2025

Matthew Walker
Chief Operating Officer
Tejon Ranch Co.
Post Office Box 1000
Tejon Ranch, California 93243

 Re: Tejon Ranch Co.
 Preliminary Proxy Statement on Schedule 14A filed March 21, 2025
 File No. 001-07183
Dear Matthew Walker:

 We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

 Please respond to these comments by providing the requested information
or advise us
as soon as possible when you will respond. If you do not believe our comments
apply to your
facts and circumstances, please tell us why in your response.

 After reviewing your response to these comments, we may have additional
comments.

PREC14A filed March 21, 2025
General

1. We note the statements on your proxy card that if you do not
specifically instruct
 otherwise, this WHITE proxy card will confer such named proxies with the
authority
 to cumulate votes among the Company Nominees you mark FOR at their
discretion
 so as to provide for the election of the maximum number of Company
Nominees,
 including the order of priority of such Company Nominees to whom such
votes may
 be allocated (emphasis omitted), and if you do not wish to grant
the named proxies
 discretionary authority to cumulate your votes in the election of
directors, you must
 indicate this on your proxy card in accordance with the instructions set
forth below.
 Please revise to clarify that, absent specific instructions to the
contrary, the named
 proxies may cumulate votes only if the proxy card is unmarked or voted
solely for
 Company Nominees, or advise.
2. Refer to comment 1. Similar disclosure appears in the third paragraph on
page three of
 the proxy statement. Please revise to clarify such disclosure in the
same manner as
 March 28, 2025
Page 2

 discussed in comment 1, or advise.
3. Refer to the following disclosure on page three: If you do not wish
to grant the proxy
 holders discretionary authority to cumulate your votes in the election
of directors, you
 must indicate this on your proxy card in accordance with the
instructions set forth
 therein. Shareholders must indicate this by checking the box on the
proxy card to
 indicate they want to cumulate on the front of the card and filling out
specific
 instructions in the space provided as to how they want their votes
allocated on the
 back of the card. No such checkbox appears to exist on the front of
the proxy card.
 Please revise or advise.
4. Please confirm that the proxy services vendor that the Company has hired
to record
 proxy votes is able to record cumulative votes, including pursuant to
specific
 cumulative voting instructions provided by shareholders in response to
the checkbox
 on your proxy card. Please also confirm that all voting platforms,
including online and
 telephone voting platforms, are able to accommodate the processing of
cumulative
 voting.
 We remind you that the filing persons are responsible for the accuracy
and adequacy
of their disclosures, notwithstanding any review, comments, action or absence
of action by
the staff.

 Please direct any questions to Blake Grady at 202-551-8573.

 Sincerely,

 Division of
Corporation Finance
 Office of Mergers &
Acquisitions
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