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CORRESP

September 5, 2017

VIA EDGAR

Securities and Exchange Commission

 Division of Corporation
Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attn:    Pamela A. Long

Re:       Loma Negra Compañía Industrial Argentina Sociedad
Anónima

 Draft Registration Statement on Form F-1

Submitted on July 12, 2017

CIK No. 1711375

Dear Ms. Long:

On behalf of our client, Loma Negra Compañía Industrial Argentina Sociedad Anónima, a company organized under the laws
of Argentina (the “Company”), we publicly file herewith Amendment No. 1 (“Amendment No. 1”) to the above-referenced draft registration statement on Form
F-1 (the “Registration Statement”) via the EDGAR system of the Securities and Exchange Commission (the “Commission”). The Registration Statement was initially submitted
confidentially to the Commission on July 12, 2017. In this letter, we set forth the Company’s responses to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Commission contained in the
Staff’s letter dated August 9, 2017 (the “Comment Letter”). In addition to the amendments made in response to the Comment Letter, the Company has also made updates in Amendment No. 1 to include certain other
information and data to reflect new developments since July 12, 2017, as well as generally to update the draft Registration Statement.

We are providing by overnight delivery a courtesy package that includes four copies of Amendment No. 1, two of which have been marked
to reflect revisions from the Registration Statement initially submitted on July 12, 2017 as well as copy of this letter.

For the Staff’s convenience, the Staff’s comments have been stated below in their entirety, with the responses to each comment
set forth immediately under the comment. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the Comment Letter from the Staff. All page numbers referenced in the responses refer to page numbers
in Amendment No. 1. Capitalized terms used but not defined herein have the meanings ascribed to such terms in Amendment No. 1.

 Securities and Exchange Commission

September 5, 2017

 General

1.
Please fill in all blanks for information not omitted in reliance on Rule 430A of the Securities Act.

Response:

 In response to the Staff’s
comment, the Company has revised the Amendment No.1 to include all information except that which can be excluded pursuant to Rule 430A of the Securities Act of 1933, as amended (the “Securities Act”).

2.
Please be advised that we may have additional comments when items that are currently blank are completed.

Response:

 The Company acknowledges that
the Staff may have additional comments when items that are currently blank are completed and will endeavor to complete or file such items in a timely manner to facilitate the Staff’s review.

3.
Please supplementally provide us with copies of all written communications, as defined in Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf, present to potential investors in
reliance on Section 5(d) of the Securities Act, whether or not they retain copies of the communication.

 Response:

As of the date of Amendment No. 1, the Company did not nor did the Company authorize anyone on its behalf to present any written
communications, as defined in Rule 405 under the Securities Act, to potential investors in reliance on Section 5(d) of the Securities Act. If the Company or anyone authorized by the Company engages in such communications in reliance on
Section 5(d) of the Securities Act, the Company will supplementally provide any such communications to the Staff.

 Special Note Regarding Non-IFRS Financial Measures, page iv

4.
We note your disclosure which states that Law 27,264, in force since August 2016, established that taxes on debits and credits to bank accounts may be applied as an advance payment of income tax. As such, please
explain why your 2016 financial statements present the tax on debits and credits to bank accounts as an operating expense in the determination of profit before tax.

Response:

 In response to the Staff’s
comment regarding Law 27,264, the Company respectfully clarifies to the Staff that its disclosure on page v states that Law 27,264 “established that small- and medium-sized companies may apply this tax as
an advance payment of income tax.” Accordingly, the Company has revised the disclosure on page v in response to the Staff’s comment to clearly state that, according to Law 27,264, the Company is a
large-sized company in Argentina, and therefore, it is only permitted to apply 0.2% on the amount levied on credits to bank accounts as an advance payment of the Company’s income tax.

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 Securities and Exchange Commission

September 5, 2017

 Prospectus Summary, page 1

5.
Please balance your disclosure with a discussion of the principal challenges or weakness and the risks and limitations facing you.

Response:

 In response to the Staff’s
comment, the Company respectfully advises the Staff that it had included in the Registration Statement on pages 12 and 13 a summary of the principal risks and challenges that it faces, and it has also included a disclaimer at the top of page 1 that
refers potential investors to the “Risk Factors” section for a more complete understanding of the risks facing the Company.

6.
We note your disclosure that your products are primarily used in construction, which you expect to be one of the fastest growing sectors of the Argentine economy in the “next years.” Please revise to
quantify.

 Response:

In response to the Staff’s comment, the Company has revised the disclosure on pages 1, 67 and 116 to quantify its expectations with
respect to the future pace of growth of the construction sector in Argentina in the next five years, which estimates are based on the Company’s current beliefs and assumptions taking into account the information currently available to it from
Consultora de Estudios Bonaerense S.A.

 Selected Operating and Financial Data, page 5

7.
Please explain the reference in footnote (1) that “control was not effective during 2016” since it appears from the notes to your consolidated financial statements that control of Yguazú
Cementos S.A. was achieved on December 22, 2016.

 Response:

In response to the Staff’s comment, the Company has revised the disclosure throughout Amendment No.1 to clarify that its control over
Yguazú Cementos S.A. became effective as of December 22, 2016 and, considering that the consolidation was not deemed significant for the 10-day period ended December 31, 2016, the Company
recorded the results of operations of its subsidiary Yguazú Cementos S.A. under the line item “share of profit (loss) of associates” in the Company’s consolidated statement of profit or loss and other comprehensive income and
cash flow statement for the six-month period ended June 30, 2016 and for the years ended December 31, 2016, 2015 and 2014.

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 Securities and Exchange Commission

September 5, 2017

 Preemptive rights, page 16

8.
We note your disclosure that the selling shareholder has preferential subscription rights, including preemptive rights in the subscription of new ordinary shares. We also note, that the selling shareholder has
communicated to you that it will not exercise its preferential rights. Please tell us whether the selling shareholder’s election to not exercise its preferential rights will be reflected in a written agreement.

Response:

 The Company acknowledges the
Staff’s comment and it respectfully informs the Staff that the selling shareholder has expressed its irrevocable decision to the Company to not exercise its preferential rights in the subscription of new ordinary shares; however, as of this
date, the Company has not received a written communication from the selling shareholder reflecting its decision. If the Company receives a written communication from the selling shareholder in this regard, the Company will supplementally provide a
copy of such communication to the Staff.

 Risk Factors, page 24

Risks Relating to the Offering, Our Ordinary Shares and the ADSs, page 39

Your voting rights with respect to the shares are limited, page 42

9.
On page 42 you state that you “will provide the notice to the depositary, which will in turn, if we so request, as soon as practicable thereafter provide to each ADS holder.” Please revise to make clear the
circumstances where you would not instruct the depositary to notify ADS holders of shareholders’ meetings or where the depositary may itself determine not to notify ADS holders.

Response:

 The Company respectfully
advises the Staff that the Company has not yet engaged a depositary for the Company’s American depositary shares as of the date hereof. The Company will revise the referenced disclosure in subsequent amendments to its Form F-1 following the Company’s engagement of a depositary.

 Use of Proceeds, page 55

10.
Please provide the disclosure required by Item 3.C.4. of Form 20-F.

Response:

 The Company advises the Staff
that it has not determined which, if any, of its outstanding indebtedness it intends to repay using the net proceeds it receives in the offering, or the aggregate amount of any such repayment. The Company acknowledges the Staff’s comment and
confirms that if it elects to discharge, reduce or retire indebtedness with any material part of the proceeds, the Company will provide the information required by Item 3.C.4. of Form 20-F.

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 Securities and Exchange Commission

September 5, 2017

 In addition, the Company has revised the disclosure on pages 17 and 55 to include additional
information, as follows: “We intend to use the net proceeds of the global offering to fund our growth plans primarily through the expansion of our L’Amalí plant, involving a total estimated investment of approximately
US$350 million (see “Business—Investments”), and for working capital and other general corporate purposes. We may also use a portion of the net proceeds of this offering to repay some of our outstanding indebtedness, although, we
have not determined which, if any, of our indebtedness we would so repay, or the aggregate amount of any repayment. Our management will have significant flexibility in applying the net proceeds of this offering.”

Selected Consolidated Financial and Other Information, page 62

11.
Please revise your presentation of the consolidated statements of financial position to clearly show that the line item “equity attributable to the owners of the Company” is a subtotal. This comment also
applies to your Summary Consolidated Financial and Other Information on page 20.

 Response:

The Company has revised the disclosure on pages 22 and 63 in response to the Staff’s comment to clearly show that the line item
“equity attributable to the owners of the Company” is a subtotal.

12.
We note that you calculate EBITDA as net profit plus finance costs, net plus income tax expense plus depreciation and amortization. However, since net finance costs consists of interest expense, exchange gains/losses
on U.S. dollar and other foreign currency- denominated debt, derivative losses or gains, and other items, your presentation of EBITDA includes items in addition to what the acronym suggests. We remind you that EBITDA is defined as “earnings
before interest, taxes, depreciation and amortization” in Question 103.01 of the SEC Compliance and Disclosure Interpretation: Non-GAAP Financial Measures
https://www.sec.gov/divisions/corpfin/guidance/nongaapinterp.htm. To the extent that you continue to add back finance costs, net, exclusive of interest items, please remove the subtotal of EBITDA in your reconciliation, as well as the references to
EBITDA throughout your draft registration statement, and solely present Adjusted EBITDA and references thereto.

 Response:

The Company respectfully acknowledges the Staff’s comment. The Company has revised the disclosure on page iv and throughout Amendment
No. 1 to clarify that the Company calculates EBITDA as net profit plus financial interest, net plus income tax expense plus depreciation and amortization and Adjusted EBITDA as EBITDA plus exchange rate differences plus other financial
expenses, net plus tax on debits and credits to bank accounts. The Company, therefore, presents the calculation of EBITDA according to the definition in Release No. 47226 and has adjusted the reconciliation of its Adjusted EBITDA to exclude
“finance cost, net” items that are not interest items.

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 Securities and Exchange Commission

September 5, 2017

13.
We refer to “net debt” and “net debt/Adjusted EBITDA ratio”. Please expand footnotes (6) and (7) to disclose the reason why these non-IFRS financial
measures provide useful information to investors, as well as any additional purposes, if any. Refer to Item 10(e)(1)(i) of Regulation S-K.

Response:

 In response to the Staff’s
comment, the Company has revised the disclosure on pages v and 65 to include, in footnotes (6) and (7) to the table showing its consolidated statement of financial position, a discussion of the principal reasons why the Company’s
management believes that net debt and the net debt/Adjusted EBITDA ratio are useful non-IFRS measures to investors. The Company has clarified that these non-IFRS
measures provide transparent and useful information to investors and financial analysts in their review of its operating performance and financial profile and in the comparison of such performance to the operating performance of other companies in
the same industry or in other industries that have different capital structures and debt levels.

 Management’s Discussion and Analysis of
Financial Condition, page 66

 General

14.
Please revise your draft registration statement to provide information regarding your research and development activities as provided by Part I, Item 5C of Form 20-F, as
applicable.

 Response:

In response to the Staff’s comment, the Company clarifies that the research and development activities that it performs have not been
material during the six-month period ended June 30, 2017 and the years ended December 31, 2016, 2015 and 2014, and that it does not have a formal policy in respect of these activities. Accordingly,
the Company has revised the disclosure on pages 11 and 123.

 Critical Accounting Policies, page 72

Intangible Assets, page 74

15.
Your disclosure states that amortization is recognized on an estimated production curve method. Please tell us and disclose in more detail, the units of measure associated with this method. In addition, disclose how
this methodology is associated with your software intangible assets or clarify your critical accounting policy as appropriate.

Response:

 In response to the Staff’s
comment, the Company has revised the disclosure on page 75 to clarify that the method of amortization of its mining exploitation rights will be determined at the time the Company begins to extract mineral from its respective quarries. Its mining
exploitation rights are of indefinite duration and have not been amortized yet. Additionally, the Company has clarified that its software intangible assets are amortized over a period of five years. The company has also included on page 75 a
reference to notes 3.9 and 14 to its audited consolidated financial statements.

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 Securities and Exchange Commission

September 5, 2017

 Year Ended December 31, 2016, Compared to the Year Ended December 31, 2015, page 76

 Share of Profit (Loss) of Associates, page 78

16.
Please expand your disclosure to more fully discuss how Yguazú Cementos recognized a loss in 2015 due to an advance payment paid to a supplier in connection with a plant construction contract.

 Response:

 In
response to the Staff’s comment, the Company has expanded its disclosure on page 84 to clarify that in 2015 its subsidiary Yguazú Cementos S.A. recorded a loss