SecProbe.io

Mail Stop 3561
April 7 , 2016

Greg L. Henslee
Chief Executive  Officer
O’Reilly Automotive,  Inc.
233 South Patterson Avenue
Springfield, MO 65805

Re: O’Reilly Automotive, Inc.
 Form 10-K for the Fis cal Year Ended December 31 , 2015
Filed February 26 , 2016
File No . 21318

Dear Mr.  Henslee :

We have limited our review of your filing to the financial statements and related
disclosures 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 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 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.

Consolidated Statements of Cash Flows, page 46

1. Please te ll us your consideration of disclosing noncash investing and financing activities
that affect recognized assets or liabilities but do not result  in cash receipts or cash
payments during each year presented.  Please refer to ASC 2 30-10-50-3.

Note 1 – Summary of Significant Accounting Policies

Segment reporting, page 47

2. We note your disclosure in Item  1 that you carry an extensive product line including new
and remanufactured automotive hard parts, maintenance items and accessories.  We also
note you offer many enhanced services and programs to your customers.  Please tell us
the significance of revenues from services and your consideration of disclosing net sales
and costs and expenses applicable to sales of tangible products and revenues from
service s on the face of the statements of income in accordance with paragraph s (b)1(a)

 Greg L. Henslee
 O’Reilly Automotive, Inc.
 April 7 , 2016
 Page 2

 and 2 of Rule 5 -03 of Regulation S -X.  In addition, please tell us what consideration you
gave to disclosing revenues for each group of similar products and services in accor dance
with ASC 280 -10-50-40.

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 Ac t rules require.   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 comment s, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commissi on 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 Scott Str inger, Staff Accountant, at ( 202) 551 -3272 or me at (202) 551 -
3344  with any questions.

Sincerely,

 /s/ William H. Thompson

William H. Thompson
Accounting Branch Chief
       Office of Consumer Products