SecProbe.io

Mail Stop 4631

October 6, 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 Compañia Industrial Argentina Sociedad Anónima
Amendment No. 1 to Registration Statement on Form F-1
Filed September 27, 2017
  File No. 333 -220347

Dear Mr. Gradin :

We have reviewed your amended 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 information .  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 stateme nt and the information you
provide in response to these  comments, we may have  additional comments.   Unless  we note
otherwise , our references to prior comments are to comments in our September 19, 2017  letter .

Description of American Depositary Shares, pag e 201

1. We note your new disclosure under this heading and have the following comments:
 We note your reference to “timely” under “Voting Rights, page 207.”   Here or under
“Your voting rights with respect to the shares are limited, page 49,” make clear any
timelines by which notice may be provided to the depositary;
 Your discussion under “Pre -release Transactions, page 211” should make clear the
“limit” on the amount of ADSs that may be outstanding as a result of pre -release
transactions.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
October 6, 2017
Page 2

 Financial State ments, page F -1

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

2. We note your response to prior comment 8.  Your response states that “the Argentine
government supervises the investments made by the concessionaire, the fulfillment of
maintenance duties, the proper use of the asset that have been granted under the
conces sion, among others”.  Given the governmental supervision and regulations over the
concession, along with the significant residual interest in the railway system being
retained by the Argentine government when the concession expires or terminates, it
contin ues to appear that your concession is within the scope of IFRIC 12 and the related
infrastructure should not be recognized as property, plant, and equipment in your
financial statements.  Please further clarify your position that the “Argentine government
does not control nor regulate the services the company may render with the
infrastructure” or otherwise modify your registration statement accordingly.

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

3. We note your response  to prior comment 11.  Please expand your footnote to disclose that
“the period of time for collection of this receivable is three years, according to the
opinion of the Company’s Argentine litigation counsel, based on the timing of the legal
and administrative procedures s till pending ” and that “t he Company expects that the
judge’s approval of the official accountant expert’s final report should occur in 2018,
according to the opinion of the Com pany’s Argentine legal advisors, ” as indicated in your
response.

You may  contac t Dale Welcome, Staff Accountant , at (202) 551 -3865  or Kevin Stertzel,
Staff Accountant,  at (202) 551 -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,

 Asia Timmons -Pierce, for

Pamela A. Long
Assistant Director
Office of Manufacturing and
Construction

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