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CORRESP
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CORRESP

 September 27, 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

Registration Statement on Form F-1

Filed on September 5, 2017

File No. 333-220347

 Dear Ms. Long:

On behalf of our client, Loma Negra Compañía Industrial Argentina Sociedad Anónima, a company organized under the laws of
the Republic of Argentina (the “Company”), we file herewith Amendment No. 1 (“Amendment No. 1”) to the above-referenced 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 and filed on September 5, 2017. In this letter, we respond to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Commission contained in
the Staff’s letter dated September 19, 2017 (the “Comment Letter”).

 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 filed on September 5, 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. 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.

 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.

 Securities and Exchange Commission

September 27, 2017

 Response:

The Company acknowledges the Staff’s comment and it respectfully informs the Staff that Loma Negra Holding GmbH has notified the Company
that, through a corporate reorganization of Cauê Áustria Holding GmbH, the sole shareholder of Loma Negra Holding GmbH and controlling shareholder of InterCement Brasil S.A., on August 26, 2017, Loma Negra Holding GmbH became the
beneficial owner of 562,883,740 of the Company’s ordinary shares, representing 99.44% of its share capital. Accordingly, the Company has revised the disclosure on pages 186 and 187 under the caption “Principal and Selling Shareholder”
to reflect this information.

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

 Response:

 In
response to the Staff’s comment, the Company has revised the disclosure in the “Prospectus Summary” section of the Registration Statement beginning on page 1 to include a discussion of the principal challenges and limitations it faces
in order to balance the information about its competitive strengths and strategies. The Company has also revised the disclosure on page 1 to include its net debt as of June 30, 2017 and December 31, 2016, and on page 6 to include its total
borrowings as of the dates indicated in the table showing certain selected consolidated financial data.

 Controlling Shareholder, page 4

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

 Response:

In response to the Staff’s comment, the Company has revised the disclosure on page 188 to include a chart setting forth the corporate
structure of the Camargo Corrêa group, in which the Company discloses the 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 required by Item 3.C.4 of Form 20-F.

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 Securities and Exchange Commission

September 27, 2017

 Response:

The Company respectfully advises the Staff that it does not intend to repay any of its outstanding indebtedness with the net proceeds it
receives from the offering. Accordingly, the Company has revised the disclosure on pages 19 and 62 to remove references to using part of the net proceeds to repay a portion of its outstanding indebtedness. Furthermore, the Company confirms that if
in the future it elects to discharge, reduce or retire indebtedness with any material part of the proceeds from the offering, the Company will revise its disclosure to include the information required 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.

Response:

 In response to the
Staff’s comment, the Company has expanded the disclosure on pages 93, 98, 102 and 103 of the Registration Statement to explain that the line item “share of profit (loss) of associates” represents the equity in profit or loss of
Yguazú Cementos S.A. (“Yguazú Cementos”), a company formed under the laws of Paraguay, for the years ended December 31, 2015 and 2014. Since share of profit (loss) in foreign companies is not taxable in Argentina,
the Company’s equity in the profit or loss of Yguazú Cementos recorded in share of profit (loss) of associates for the years ended December 31, 2015 and 2014 was not taxable. Accordingly, the adjustment for share of profit (loss) of
associates subtracts or adds, as applicable, the amount of the effect of different statutory income tax rate in Paraguay, which is calculated by multiplying the profit before income tax expense of Yguazú Cementos by 25%, which is the
difference between the 35% Argentine statutory income tax rate and the 10% of Paraguayan statutory income tax rate, from the calculation for the Company’s effective income tax.

Additionally, the disclosure on pages 93, 98, 102 and 103 has been expanded to clarify that the material fluctuations between the years ended
December 31, 2014, 2015 and 2016 are due to losses recorded by Yguazú Cementos in 2015 generated by (i) the 25% depreciation of the Paraguayan guaraní against the U.S. dollar in 2015 as compared to a 1% depreciation of the
guaraní against the U.S. dollar in 2014 and its impact on Yguazú Cementos’ U.S. dollar-denominated indebtedness and related financial expenses; and (ii) a loss of US$6.3 million recorded by Yguazú Cementos in 2015
relating to an advance payment made to Satarem AG, an engineering, procurement and construction contractor that subsequently made a voluntary bankruptcy filing. As a result of that filing, Yguazú Cementos determined that the advance payment
would not be recoverable.

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 Securities and Exchange Commission

September 27, 2017

 Furthermore, material fluctuations for the share of profit (loss) of associates between the
six months ended June 30, 2016 and 2017 are due to the consolidation of Yguazú Cementos into the Company’s financial statements beginning on January 1, 2017.

Certain Relationships and Related Party Transactions, page 183

Other Transactions, page 184

6.
We note that you have accepted 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.

 Response:

In response to the Staff’s comment, the Company has revised the disclosure on page 191 to elaborate on the terms of the offer received by
Cimpor—Serviços De Apoio à Gestão De Empresas S.A. (“Cimpor”) in connection with services related to the transfer of technology and technical know-how to be used in
the manufacture and production of cement products, which the Company accepted on August 17, 2017. Furthermore, the Company has filed as an exhibit to Amendment No. 1 a copy of the agreement with Cimpor.

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 ASC805-50-45, since the acquisition of Yguazú Cementos was accounted for as a business combination of entities under common control.

Response:

 In response to the
Staff’s comment, the Company respectfully advises the Staff that, in the absence of specific IFRS guidance applicable to the Yguazú Cementos transaction, the Company has applied the requirements of IAS 8.10 – 12 and has used its
judgment in developing and applying an accounting policy for the transaction.

 The accounting policy of the Company regarding business
combinations between entities under common control establishes that:

•

The assets and liabilities of the acquired entity are recognized at the book values recorded in the ultimate parent entity’s consolidated financial statements and any differences, if any, with respect to the
purchase price is recorded within equity in the “Other capital adjustments” account.

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 Securities and Exchange Commission

September 27, 2017

•

For reporting purposes, the Company reflects these transactions prospectively and does not restate the information for any period presented in its consolidated financial statements prior to the business combination
date. As a basis for this presentation, the Company notes the following:

•

The Company does not believe that it is required to retrospectively reflect business combinations of entities under common control that do not result in the change in the reporting entity; and

•

There are no local legal requirements that require entities to effect a restatement of comparative periods prior to the date of acquisition.

Based on the factors mentioned above, the Company has revised the disclosure on pages F-55 and F-56 to remove the references to U.S. GAAP and the pooling-of-interest method in order to avoid potential misunderstanding.

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 Ferrosur 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 terms of your 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 the 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.

 Response:

The Company acknowledges the Staff’s comment and respectfully informs the Staff the following:

•

General description of the terms and conditions of the Ferrosur Roca S.A. (“Ferrosur”) railway concession:

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 Securities and Exchange Commission

September 27, 2017

•

Regulatory framework: The concession of the railway freight transport service granted by the Argentine government (the “Grantor”) to Ferrosur is governed by the following regulations: (i) the Concession
Bidding Terms and Conditions (the “Bidding Conditions”); (ii) the Concession Agreement for the Comprehensive Operation of the National Railway Network Area comprised of the former General Roca Line, excluding the Altamirano-Miramar
corridor and its urban sections, dated December 3, 1992 (the “Concession Agreement”), approved by Executive Order 2681/1992, dated December 19, 1992 and published in the Official Gazette (Boletín Oficial)
on January 8, 1993; and (iii) Minutes of Agreement, dated May 19, 2008, executed between the Unit for Renegotiation and Review of Public Utility Contracts (Unidad de Renegociación y Análisis de Contratos de
Servicios Públicos or “UNIREN”) and Ferrosur (the “Minutes of Agreement”), as ratified by Executive Order 2017/2008, dated November 25, 2008, and published in the Official Gazette (Boletín
Oficial) on December 3, 2008.

•

Ferrosur’s share capital structure: The Bidding Conditions set forth the composition of Ferrosur’s share capital, which cannot be modified by the shareholders, as follows: (i) Class “A” shares
representing 16% of its share capital, held by Ferrocarriles Argentinos, an Argentine governmental entity; (ii) Class “B” shares representing 4% of its share capital, held by Ferrosur’s employees; and (iii) Class
“C” shares representing the remaining 80% of its share capital, held by Cofesur S.A., a wholly-owned subsidiary of the Company, as of June 30, 2017.

•

Term of the concession: The Bidding Conditions provide that the concession’s term is 30 years from March 11, 1993; therefore, the concession’s term expires on March 11, 2023. The Bidding Conditions
further provide that Ferrosur may request an extension of the term for additional 10 years by delivering a notice to the Ministry of Transport (Ministerio de Transporte) at least five years prior to the expiration date.

•

General obligations of the concessionaire: Ferrosur’s main obligations under the applicable regulations are: (i) to maintain a contract performance bond in an amount equivalent to 10% of the bid originally
submitted by Cofesur S.A.; (ii) to pay the concession fee equal to 3% of the total annual net revenue for the previous fiscal year, allocating 30% thereof to the Argentine Social Security System (Administración Nacional de la Seguridad
Social) and the remaining 70% to the Trust Fund for Inter-Urban Railway System Support (Fondo Fiduciario de Fortalecimiento del Sistema Ferroviario Interurbano or “FFFSFI”), which can be used by Ferrosur for capital
expenditures for infrastructure investments in the railway network under the concession, subject to certain conditions and limitations; (iii) to invest 10.7% of the total annual net revenue for the previous fiscal year in the railway
network under the concession; (iv) to maintain the concession’s infrastructure and to file annually with the Federal Transport Commission (Comisión Nacional de Regulación del Transpor