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Correspondence

 Universal Corporation

 1501 North Hamilton Street

 Richmond, Virginia 23230

 February 27, 2009

 Via EDGAR

 Securities and Exchange Commission

 100 F Street, N.E.

 Mail Stop 7010

 Washington, D.C. 20549

 Attention: Juan Migone

          Division of Corporation Finance

Re:

Universal Corporation

Form 10-K for the fiscal year ended March 31, 2008

Filed May 30, 2008

File Number 001-00652

 Dear Mr. Migone:

 As Controller and Principal Accounting Officer of Universal Corporation, a Virginia corporation (the “Company”), I am transmitting herewith for filing the Company’s response to the comments of the staff (the
“Staff’) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”) contained in its comment letter dated February 13, 2009 (the “Commission Comment Letter”). When used in
this letter, the “Company,” “we,” “us,” and “our” refer to Universal Corporation.

 Set forth below are the
responses of the Company to the comments of the Staff. For convenience of reference, each Staff comment is reprinted in italics, numbered to correspond with the paragraph numbers assigned in the Commission Comment Letter, and is followed by the
corresponding response of the Company.

 If a comment has requested the Company provide the Staff with additional information so that the Staff may better
understand the Company’s disclosure, it is set forth after the applicable comment. The Company confirms that it will comply with all other comments in future filings as set forth below.

 Securities and Exchange Commission

 February 27, 2009

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 2

 Form 10-K for the fiscal year ended March 31, 2008

 Cover

1.
In future filings, please include the complete registration file number on the cover to the Form 10-K.

 Response:

 We
acknowledge the Staff’s comment. In response to the Staff’s comment, we will include the complete registration file number (001-00652) on the cover of the Annual Report on Form 10-K in all future filings.

 Item 7-Management’s Discussion and Analysis of Financial Condition and Results of Operations

 Results of Operations, page 20

2.
We note you have three reportable segments. We also note that you have included the results of unconsolidated affiliates in segment reporting income, but not in consolidated
operating income, in note 14 of your financial statements. Therefore, in order to provide a better understanding of the factors underlying the changes in your results of operations, please revise your discussion to focus on each of your reportable
segments separately from the discussion of your consolidated operating results. See Item 303(a) of Regulation S-K for guidance.

 Response:

 We acknowledge the Staff’s comment. In response to the Staff’s comment,
in future filings with the Commission, our Results of Operations discussion will focus on each reportable segment separately from the discussion of our consolidated operating results.

3.
Additionally, we note that your discussion of results of operations is limited to the context of income from continuing operations, which does not address your sales or expenses
directly. However, we believe your disclosures should be supplemented with, or preferably replaced by, a discussion and analysis of sales and costs on a stand-alone basis (not in the context of income from continuing operations) for each segment and
as a whole. Further, we believe such disclosure should include separate quantification and discussion of changes in significant components of costs of revenues.

 Response:

 We
acknowledge the Staff’s comment. In response to the Staff’s comment, in future filings with the Commission, our Results of Operations discussion will be revised to discuss sales and costs on a standalone basis for each reportable segment
and as a whole. This discussion will separately quantify and discuss changes in significant components of costs and revenues.

 Securities and Exchange Commission

 February 27, 2009

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 3

 Item 8-Financial Statements and Supplementary Data

 Consolidated Statements of Income, page 33

4.
Your current presentation does not appear to comply with Rule 5-03(13) of Regulation S-X. As such please provide us with significant support for your current presentation of
equity in pretax earnings of unconsolidated affiliates.

 Response:

 We acknowledge the Staff’s comment. In response to the Staff’s comment, we provide the following additional information to the Staff related to
our investments in unconsolidated affiliates, our presentation of equity in the earnings of those affiliates in our consolidated financial statements, and our interpretation of the accounting and reporting guidance applicable to this area. From a
historical perspective, we reported equity earnings from unconsolidated affiliates on an after-tax basis in our consolidated financial statements through our fiscal year 1997. During fiscal year 1998, we formed Socotab, L.L.C., an oriental tobacco
joint venture, with a closely-held business partner in Europe. To form the joint venture, we contributed our ownership in oriental tobacco operations in Turkey, and our partner contributed oriental tobacco operations it owned in Turkey and several
other European countries. We received a 49% ownership interest in the newly-formed venture, with our business partner owning 51%. Considering the respective ownership interests and all other factors relevant to the accounting and reporting for the
joint venture investment, we determined that application of the equity method under Accounting Principles Board Opinion No. 18, “The Equity Method of Accounting for Investments in Common Stock” (“APB 18”), was appropriate.
At that time, we changed our reporting presentation to show our equity in the earnings of unconsolidated affiliates on a pretax basis in our consolidated income statement. With this presentation change, our equity in the income tax expense recorded
on Socotab’s books, plus the additional U.S. tax expense accrued on Socotab’s earnings expected to be distributed to us and repatriated to the United States, were recorded in income tax expense in our consolidated income statement. We
adopted this presentation change for the following reasons:

1.
Socotab’s operations are in our core business. Oriental tobaccos are a key component of American blend cigarettes, and the major customers buying those tobaccos from Socotab
are largely the same ones that buy other types of American blend tobaccos from our various consolidated subsidiaries. Our management believed at that time, and continues to believe today, that this approach provides better consistency and a clearer
presentation of our interest in the oriental tobacco operations as a component part of our larger tobacco business.

 Securities and Exchange Commission

 February 27, 2009

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 4

2.
Our investments in unconsolidated affiliates other than Socotab were immaterial, and they remain so today; therefore, the amounts reported for unconsolidated affiliates in our
financial statements relate almost entirely to the investment in Socotab.

3.
Internal management reporting to our chief operating decision-maker was, and continues to be, based on equity in the pretax earnings of our unconsolidated affiliates. Accordingly,
the presentation of financial results for our reportable operating segments under the guidance in FASB Statement No. 131 includes the equity in earnings of unconsolidated affiliates on a pretax basis.

4.
Socotab’s operations are based primarily outside the U.S., and it declares annual dividends to distribute all or most of its earnings to its shareholders. We assume
repatriation of our share of Socotab’s earnings and provide U.S. federal income taxes on those earnings at the 35% U.S. corporate tax rate, net of the foreign tax credit we expect to realize on our allocated share of the income taxes Socotab
pays outside the United States. In presenting equity in earnings of unconsolidated affiliates on a pretax basis, both the foreign and domestic income taxes applicable to our investment in Socotab are reported in income tax expense. Our management
believed at the time, and continues to believe today, that this presentation is clearer and more easily understood by investors and analysts.

 Before adopting this change in reporting presentation during fiscal year 1998, we considered the applicable accounting and reporting guidance. Rule 5-03(13) of Regulation S-X addresses the income statement line item
for “equity in earnings of unconsolidated subsidiaries and 50 percent or less owned persons”. In the sequence of line items outlined in Rule 5-03 of Regulation S-X, this line follows pretax earnings, income taxes, and minority interest,
and it comes before income from continuing operations. As such, we agree with the presumption that equity in earnings of unconsolidated subsidiaries is reported based on the after-tax earnings of the unconsolidated entity, and we acknowledge that is
the common practice. However, Rule 5-03(13) does state specifically for reporting equity in earnings of unconsolidated affiliates that “if justified by the circumstances, this item may be presented in a different position and a
different manner” (emphasis added). In addition, APB 18, paragraph 19.c., states that “the investment(s) in common stock should be shown in the balance sheet of an investor as a single amount, and the
investor’s share of earnings or losses of an investee should ordinarily be shown in the income statement as a single amount…” (emphasis added). Based on this guidance, we believed
during fiscal year 1998, and we continue to believe, that companies are permitted to modify their income statement presentation for equity in earnings of unconsolidated affiliates when factors support a different presentation.

 We believe investors and analysts fully understand our reporting presentation, and they have never raised any questions or issues with it over the eleven
year period it has been used. We believe it would be confusing to financial statement users to change the presentation at this time. Our responses to the Staff’s comments numbered 5, 6, 7, and 10 that follow in this letter provide further
information regarding our investments in unconsolidated affiliates and our related reporting presentation. As previously noted, we

 Securities and Exchange Commission

 February 27, 2009

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believe that our current income statement presentation continues to be clearer and more understandable to readers of our financial statements. If the Staff
concurs with our preference to continue this presentation, then we will include a reconciliation of our equity in the pretax earnings of unconsolidated affiliates to the related after-tax amounts in the notes to the consolidated financial statements
in all future annual filings with the Commission on Form 10-K, similar to the table provided below in our response to the Staff’s comment number 6.

5.
Based on the amounts reported on your consolidated statements of cash flows, it appears that your equity in the net income of the unconsolidated affiliates differs significantly
from the equity in pretax earnings of unconsolidated affiliates as reported on the consolidated statements of income. Please tell us why you believe it is appropriate to report your share of the earnings of unconsolidated affiliates on a pretax
basis prior to the subtotal for “income before taxes and other items”, while the tax impact associated with these unconsolidated affiliates is reported within “income taxes”. In this regard, we note your presentation is not
consistent with your presentation of your minority interests, net of income taxes.

 Response:

 We acknowledge the Staff’s comment. We refer to our response to the Staff’s comment number 4 above for a detailed explanation
of our belief that it is appropriate to report our share of the earnings of unconsolidated affiliates on a pretax basis before the subtotal for “income before taxes and other items”, while the tax impact associated with our unconsolidated
affiliates is reported within “income taxes”.

 With respect to the presentation of minority interests, net of income taxes, in our
consolidated income statement, we do not interpret the relevant guidance in Accounting Research Bulletin No. 51, FASB Statement No. 94, and Rule 5-03(14) of Regulation S-X to allow alternative presentations. Our minority interests are
significantly smaller than our investments in unconsolidated affiliates. Additionally, the primary reasons that we believe it is appropriate to present equity in the earnings of unconsolidated affiliates on a pretax basis do not apply to our
minority interests (for example, consistency with internal management reporting and segment reporting). Further, we will be adopting FASB Statement No. 160, “Noncontrolling Interests in Financial Statements – an amendment of ARB
No. 51”, at the beginning of our upcoming fiscal year 2010 (i.e., April 1, 2009), which will mandate changes in the income statement and balance sheet presentations for minority interests.

 Securities and Exchange Commission

 February 27, 2009

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 Consolidated Statements of Cash Flows, page 36

6.
Please provide us with a reconciliation of your reported equity in net income of unconsolidated affiliates, net of dividends, to the equity in pretax earnings of unconsolidated
affiliates as reported in your consolidated statements of income. Also, consider the need to present such a reconciliation in future filings.

 Response:

 We acknowledge the Staff’s comment. In response to the
Staff’s comment, the following table provides a reconciliation of our equity in the pretax earnings of unconsolidated affiliates, as reported in our consolidated statements of income, to our equity in the net income of unconsolidated
affiliates, net of dividends, as reported in our consolidated statements of cash flows for the fiscal years ended March 31, 2008, 2007, and 2006:

Fiscal Year Ended March 31,

2008

2007

2006

 Equity in pretax earnings of unconsolidated affiliates reported in the consolidated statements of income

$
13,500,347

$
14,234,698

$
14,139,900

 Equity in income taxes of unconsolidated affiliates

2,943,784

2,274,463

3,960,576

 Equity in net income of unconsolidated affiliates

10,556,563

11,960,235

10,179,324

 Less: Dividends received on investments in unconsolidated affiliates *

(11,164,276
)

(10,806,915
)

(21,845,071
)

 Equity in net income of unconsolidated affiliates, net of dividends

(607,713
)

1,153,320

(11,665,747
)

 Reconciling item in 2007 **

—

(500,000
)

—

 Equity in net income of unconsolidated affiliates, net of dividends, reported in the consolidated statements of cash flows

$
(607,713
)

$
653,320

$
(11,665,747
)

*
In accordance with FASB Statement No. 95, all dividends received from unconsolidated affiliates accounted for on the equity method represent a return on capital (i.e., a return
of earnings on a cumulative basis) and are presented as operating cash flows.

**
A $500,000 adjustment to equity in the pretax earnings of unconsolidated affiliates was incorrectly recorded as selling, general, and administrative expense in the income statement
in fiscal year 2007. It should have been reported in equity in the pretax earnings of unconsolidated affiliates. The amounts reported in the consolidated statement of cash flows are correct.

 As noted above in our response to the Staff’s comment number 4, if the Staff concurs with our preference to maintain our current presentation of
equity in the earnings of unconsolidated affiliates on a pretax basis, then we will include this or a similar reconciliation in the notes to the consolidated financial statements in all future annual filings with the Commission on Form 10-K.

 Securities and Exchange Commission

 February 27, 2009

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 Notes to Consolidated Financial Statements

 In