SecProbe.io

Mail Stop 4631

September 19, 2017

Marcos Gradin
Chief Financial Officer
Loma Negra Compañía Industrial Argentina Sociedad Anónima
Reconquista 1088, 7th Floor
Ciudad Autónoma  de Buenos Aires, Argentina
Zip Code C1003ABQ

Re: Loma Negra Compañía Industrial Argentina Sociedad Anónima
Registration Statement on Form F -1
Filed September 5, 2017
  File No. 333 -220347

Dear Mr. Gradin :

We have reviewed your registration statement  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 by amending your registration statement and providing the
requested informati on.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provid e in response to these  comments, we may have  additional comments.

General

1. We note your response to prior comment 36.  Please tell us and revise your registration
statement to disclose the date that Loma Negra Holding GmbH became the owner of
99.44% of your outstanding capital stock through a corporate reorganization.

Prospectus Summary, page 1

2. We note your response to comment 5 of our letter dated August 9, 2017.  Please ensure
that the information you include in your summary is balanced, such as more  prominent
disclosure of your indebtedness.  To the extent you cite competitive strengths and
strategies in your summary, please review each one and revise as necessary to provide

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
September 19, 2017
Page 2

 balancing information rather than merely listing generalized risk factors at  the end of this
section.

Controlling Shareholder, page 4

3. We note your disclosure  on page 181.  Please revise your disclosure here to reflect Cauê
Áustr ia Holding GmbH’s ownership of Loma Negra Holding GmbH as well as
InterCement Participações S.A.’s ultimate ownership of Loma Negra Holding GmbH.

Use of Proceeds, page 61

4. We note your response to comment 10 of our letter dated August 9, 2017.  Please remove
your disclosure regarding use of the proceeds to repay your indebtedness until you can
revise such section to include the information re quired by Item 3.C.4 of Form 20 -F.

Management’s Discussion and Analysis of Financial Condition, page 75

Year Ended December 31, 2016, Compared to the Year Ended December 31, 2015, page 92

Income Tax Expense, page 99

5. We note your response to prior comment 17 and the revision to your registration
statement; however, it is unclear what the adjustment for the share of profit (loss) of
associates represents.  Please expand your disclosure to discuss the nature of this item,
such as whether it represents  an adjustment for a foreign tax rate differential, as well as
the reason for the material fluctuation between comparative periods.

Certain Relationships and Related Party Transactions, page 183

Other Transactions, page 184

6. We note that you have accepte d an offer from Cimpor - Serviços De Apoio à Gestão De
Empresas S.A. regarding services to be received in connection with the transfer of
technology and technical know -how.  Please elaborate on the terms on this arrangement.
Please file your agreement with  Cimpor as an exhibit.  Refer to Instruction 4(b)(1) of the
Instructions as to Exhibits of Form 20 -F.

Financial Statements, page F -1

2. Basis of Preparation of the Consolidated Financial Statements, page F -48
2.3.1. Business combination between entities under common control, page F -55

7. We note your response to prior comment 37.   Please further explain how you determined
it was appropriate to not present your historical financial statements as provided in ASC

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
September 19, 2017
Page 3

 805-50-45, since the acquisition of Yguazú Cem entos was accounted for as a business
combination of entities under common control.

4. Critical Accounting Judgments and Key Sources Used for Estimating Uncertainty,
page F -74
4.1.1. Concession of Ferrosur Roca S.A., page F -74

8. We note your response to prior comment 38.  To help us better understand your
conclusion that the concession of Ferrosur Roca S.A. is not within the scope of IFRIC 12,
please:
 Provide us with a general description of the terms and conditions of the Ferrosu r Roca
S.A. railway concession ;
 Tell us the public service nature of the obligations you have undertaken via your
concession agreement;
 Tell us to what extent you operate the assets under the concessions for your own use ;
 With reference to the specific ter ms of you r agreement with the Argentine
government, please tell us your basis for the statement that “the grantor of the
concession does not control or regulate the services the operator must provide with
the infrastructure ;” and
 Based upon the terms of th e concession agreement, please tell us whether the
Argentine government retains any significant residual interest in the railway system
when the concession expires in 2023 or if the agreement is terminated.

19. Parent Company, Other Shareholders, Associat es, and Other Related Parties Balances and
Transactions, page F -90

9. We note your  response to prior comment 40; h owever, it appears to us that in addition to
short -term employee benefits, key management personnel compensation refers to post -
employment benef its, other long -term benefits, termination benefits, and share -based
compensation.  We also remind you that  key management extends beyond the board of
directors as indicated in paragraph 9 of IAS 24.  In this regard, please revise your
footnote  to prov ide the disclosures required by paragraph 17 of IAS 24.

21. Trade Accounts Receivable, page F -94

10. We note your response to prior comment 41.  Please expand your footnote with respect to
the railway program receivable to disclose:
 That the receivable is not co nsidered past -due and has been classified as “to become
due” because it relates to the proceeds a claim;
 When the receivable will become due; and
 The terms of the receivable and your estimated collection schedule, as previously
requested.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
September 19, 2017
Page 4

 36. Receivable from Railway Program Execution Unit, page F -116

11. We note your response to prior comment 42.  Please tell us whether a judge has approved
the claim of Ps.78 million or when you expect this to occur.

Trust of Administration, page F -116

12. We note your response to prior comment 43 and have the following additional comments:

 Please more fully explain to us how you determined the likelihood of the collection of
funds from the Ministry of Transportation is certain and that such amounts will be
provided to your suppliers f or costs that you incur to improve the railroad system.

 It remains unclear to us how you determined that a Ps84 million gain was appropriate
for the year ended December 31, 2016 based upon operating expenses that you
incurred in prior peri ods.  Please tell us which accounts were impacted by your gain
recognition and how IAS 37 supports your conclusion.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding requests for  accel eration .  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

You m ay contact Dale Welcome, Staff Accountant,  at (202)  551-3865  or Kevin Stertzel,
Staff Accountant,  at (202) 55 1-3723  if you have questions regarding comments on the financial
statements and related matters.  Please contact Sergio Chinos, Staff Attorney,  at (202) 551 -7844
or me at (202) 551 -3754  with any other questions.

Sincerely,

 /s/ Asia Timmons -Pierce,  for

 Pamela A. Long
Assistant Director
Office of Manufacturing and
Construction

cc: John R.  Vetterli, Esq.
 John P. Guzman, Esq.