SecProbe.io

March 7, 2011

George C. Freeman, III Chairman, President and Chief Executive Officer Universal Corporation 9201 Forest Hill Avenue Richmond, VA  23235
Re: Universal Corporation  Form 10-K for the Fiscal Year Ended March 31, 2010
Filed May 27, 2010 Definitive Proxy Statement on Schedule 14A Filed June 29, 2010 File No. 001-00652
 Dear Mr. Freeman:
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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.  Form 10-K for the Fiscal Year Ended March 31, 2010

Exhibits 31.1 and 31.2

1. We note the identification of the certif ying individual at the beginning of each
certification required by Item 601(b) (31) of Regulation S-K also includes the title of each
certifying individual.  In future filings, the identification of the certifying individual at the
beginning of each certification should be revise d so as not to include such individual’s
title.

George C. Freeman, III Universal Corporation March 7, 2011 Page 2

Definitive Proxy Statement on Schedule 14A

Summary Compensation Table, page 34

2. We note that you provided matching gifts for your named executive officers for the fiscal
year ending on March 31, 2010.  As the total amo unt of all perquisite s or other personal
benefits for an individual named executive o fficer is more than $10,000, please revise, in
future filings, the Summary Compensation Table to include the amounts of such matching gifts for each named executive offi cer.  Refer to Item 402(c)(2)(ix) of
Regulation S-K.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure in the filing;

• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

• the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Please contact Donald E. Field at (202) 551-3680 or me at (202) 551-3642 with any
questions.

Sincerely,

Lauren Nguyen Attorney-Advisor