SecProbe.io

March 13, 2015

Thomas McF all
Chief Financial Officer
O’Reilly Automotive, Inc.
233 South Patterson Avenue
Springfield, Missouri 65802

Re: O’Reilly Automotive, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2014
Filed February 27, 2015
File No. 0-21318

Dear Mr. McFall :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comment .  In our comment , we may ask you  to provide us
with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comment applies  to your facts and circumstances, please tell us why in your response.

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

Item 8.  Financial Statements and Supplementary Data

Note 1 – Summary of Significant Accounting policies, page 46

1. We note your disclosure on page 9 that you maintain a loyalty program providing
members the opportunity to earn points which may be redeemed toward coupons for
discounts on future purchases.  Please tell us how you  account for your customer loyalty
program and your consideration of disclosing your accounting policy specifically as it
relates to the program.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be  certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsib le for the accuracy
and adequacy of the disclosures they have made.

  Thomas McFall
  O’Reilly Automotive, Inc.
 March 13, 2015
  Page 2

  In responding to our comment , please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in th e 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 federal securities laws of the United States.

You may contact  Donna Di Silvio, Staff Accountant,  at (202) 551 -3202  or me at (202)
551-3344  with any questions.

Sincerely,

 /s/ William H. Thompson

       William H. Thompson
       Accounting Branch Chief