SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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 June 24, 2025

Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG Ciudad Aut noma de Buenos Aires
Republic of Argentina

 Re: Loma Negra Compania Industrial Argentina Sociedad Anonima
 Form 20-F for the Year Ended December 31, 2024
 Filed April 29, 2025
 File No. 001-38262
Dear Marcos Gradin:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of Corporation
Finance
 Office of Manufacturing
</TEXT>
</DOCUMENT>

CORRESP
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 Document June 20, 2025 U.S. Securities and Exchange Commission Division of Corporation Finance Office of Manufacturing Attn: SiSi Cheng and Hugh West Re: Loma Negra Compañía Industrial Argentina Sociedad Anónima Form 20-F for the Fiscal Year Ended December 31, 2024 Filed April 29, 2025 File No. 001-38262 Dear Ms. Cheng and Mr. West: We hereby acknowledge receipt of your letter dated June 12, 2025 (the “Letter”), containing comments from the Staff of the Division of Corporation Finance regarding our Form 20-F for the fiscal year ended December 31, 2024. Comment 1 – Revenues (Item 5.A of Form 20-F) We hereby acknowledge the Staff’s comment regarding the need for a more robust and informative discussion of changes in revenue by segment, including explanations of the material variations in volume and pricing. In future filings, we will revise and supplement our disclosure in the Operating and Financial Review and Prospects section as set forth in your Letter. Sincerely, By: /s/ Marcos I. Gradin Name: Marcos I. Gradin Title: Chief Financial Officer Loma Negra Compa ñía Industrial Argentina Sociedad An ó nima

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 12, 2025

Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG Ciudad Aut noma de Buenos Aires
Republic of Argentina

 Re: Loma Negra Compania Industrial Argentina Sociedad Anonima
 Form 20-F for the Year Ended December 31, 2024
 Filed April 29, 2025
 File No. 001-38262
Dear Marcos Gradin:

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

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Year Ended December 31, 2024
Item 5 - Operating and Financial Review and Prospects
A. Operating Results
Year Ended December 31, 2024, Compared to the Year Ended December 31, 2023
Revenues, page 87

1. We note your narrative discussion of the changes in revenue by segment.
Please revise
 your future filings to address the following items.
 Provide a more robust and informative discussion regarding the
reasons for the
 material increases/decreases in revenues for the periods presented.
For example,
 address the underlying reasons for the 24% decrease in sales volume
in the
 Cement segment, as well as the 32% decrease in sales volume and 8%
decrease in
 the average sales price in the Concrete segment.
 Supplement your narrative discussion with a price, volume, mix
analysis,
 preferably in tabular and comparative format. In this regard, we note
you present a
 June 12, 2025
Page 2

 table of segment sales volumes in your 6-K furnished on March 7, 2025
 (see Exhibit 1, page 6).
 Clarify whether the changes identified are trends that are
reasonably likely to
 impact future revenues.
 Refer to Item 303(b)(2) of Regulation S-K and SEC Release No. 33-3850.
 In closing, 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.

 Please contact SiSi Cheng at 202-551-5004 or Hugh West at 202-551-3872
with any
questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
March 23, 2023
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the Year Ended December 31, 2021
File No. 1-38262
Dear Marcos Gradin:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    March 6, 2023

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street, N.E.

    Washington, D.C. 20549

            Attn:

              Ken Schuler, Craig Arakawa, Mindy Hooker, Kevin Stertzel

          Re:

            Loma Negra Compañía Industrial Argentina Sociedad Anónima Amendment No. 1 to Form 20-F for the Year Ended December 31, 2021 File No. 1-38262

    Ladies and Gentlemen:

    Loma Negra Compañía Industrial Argentina Sociedad Anónima (the “Company”) is submitting this letter in response to the comment letter dated February 17, 2023 (the “Comment Letter”) issued by the staff of
      the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the Form 20-F for the year ended December 31, 2021, as filed with the Commission on April 29, 2022 (the
      “Form 20-F”), and as amended by Amendment No. 1 as filed with the SEC on December 28, 2022 (“Amendment No. 1”).

    To facilitate the Staff’s review, the text set forth below in bold-faced type, immediately following each paragraph number, is a reproduction of the comments included in the Comment Letter. Except as otherwise indicated,
      all references to page numbers and captions (other than those in the Staff’s comments) correspond to the page numbers and captions in the copy of Amendment No. 1. Capitalized terms used and not otherwise defined herein shall have the meanings set
      forth in Amendment No. 1.

    Amendment No. 1 to Form 20-F for the Year Ended December 31, 2021

    Overview of Mineral Reserves, page 4

              1.

              We reviewed your reserve disclosure and noted the sale price for your salable products, which serve as a basis of your reserve determination, was not disclosed in your filing as required the footnotes to Tables
                1 and 2 of paragraph (b) for Item 1303 of Regulation S- K. In addition, the metallurgical recoveries were not disclosed for your material properties as required by Items 1304(d)(1) of Regulation S-K. Please modify your filing and include
                these modification factors for each of your properties with your reserve tables.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Location and History, page 5

              2.

              We note your individual material property disclosure beginning in this section. Please modify your filing and locate each of your material properties within one mile, using an easily recognizable coordinate
                system to comply with Item 1304(b)(1)(i) of Regulation S- K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Facilities, page 9

              3.

              Please modify your filing and include the book value for your material property as required by Item 1304(b)(2)(iii) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1

      La Pampita y Entorno Quarry, page 8

              4.

              Please modify your filing to locate your property to within one-mile using an easily recognizable coordinate system. In addition, please enlarge your maps and illustrations to make them legible as required by
                Item 601(B)(96)(iii)(b)(3)(i) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1

      Geological Units involved in the project, page 14

              5.

              Please modify your filing to provide a cross-section of the local geology as required by Item 601(B)(96)(iii)(b)(6)(iii) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1

      Adequacy of the Test Data, page 26

              6.

              We reviewed the mineral processing section of your technical report summary. Please modify your filing to include the QP’s opinion on the adequacy of the data and state the metallurgical recovery as required by
                Item 601(B)(96)(iii)(b)(10)(v) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1

      Reserves Estimation, page 30

              7.

              We note you did not disclose a reserve price or metallurgical recovery for your reserve estimates. Please state the price and recovery used to determine your reserves and disclose, with particularity, the
                reasons this price was selected and any assumptions underlying this selection. See Item 601(B)(96)(iii)(b)(12)(iii) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1

      Annual Production Rate, page 35

              8.

              Please modify your technical report to provide the annual Life of Mine (LOM) production schedule for your limestone and waste production as required by Item 601(B)(96)(iii)(b)(13) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

      2

    Exhibit 96.1

      Market Studies, page 40

              9.

              We note you did not disclose a commodity price forecast in the section. Please modify your technical report to disclose your cement price projections and the basis for your commodity price forecast as used in
                your economic evaluation as required by Item 601(B)(96)(iii)(b)(16) of Regulation S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1 A

      Capital and Operating Costs, page 43

              10.

              We note you did not disclose an accuracy estimate with your capital and operating cost estimates as required by Item 601(B)(96)(iii)(b)(18)(i) of Regulation S-K.
                Please modify your filing to include your accuracy estimate and discuss how the annual operating costs in this section relate to the operating costs presented in the economic analysis.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    Exhibit 96.1 A

      Economic Viability, page 44

              11.

              Please modify your technical report to include the annual mined material tonnage in your cash flow analysis as required by Item 601(B)(96)(iii)(b)(19) of Regulation
                S-K.

    The Company respectfully acknowledges the Staff’s comment and proposes to revise the disclosure as shown in the appendix to this letter in response.

    * * *

      3

    We appreciate in advance your time and attention to our responses.  Should you have any additional questions or concerns, please contact John Guzman of White & Case LLP at +55 11 3147 5607 or Scott Levi of White
      & Case LLP at +1 212 819 8320.

            Very truly yours,

            /s/ Marcos I. Gradin

            Marcos I. Gradin

            Chief Financial Officer

            Loma Negra Compañía Industrial Argentina Sociedad Anónima

    cc:            Sergio D. Faifman, Chief Executive Officer

    Loma Negra Compañía Industrial Argentina Sociedad Anónima

    John Guzman, Esq.

    Scott Levi, Esq.

    White & Case LLP

      4

    Appendix

    Draft disclosure in response to comment 1.

    Summary of our Mineral Reserves as of December 31, 2021

              Proven mineral reserves

              Probable mineral reserves

              Total mineral reserves

              Amount

              Grades/

              Qualities

              Amount

              Grades/

              Qualities

              Amount

              Grades/

              Qualities

            (Million Tonnes)

            (% CaO)

            (Million Tonnes)

            (% CaO)

            (Million Tonnes)

            (% CaO)

            Limestone:*

            Doña Amalía

            53.6

            43.96

            56.2

            44.6

            109.8

            44.2

            Piedras Blancas

            0.3

            50.9

            0.3

            50.9

            0.6

            50.9

            El Salitral y Cerro Bayo

            31.5

            44.1

            48.4

            43.7

            79.9

            43.8

            Barker

            44.5

            46.4

            27

            46.1

            71.5

            46.2

            La Pampita y Entorno** (Don Gabino –

             Los Abriles – SASII)

            591.4

            47.4

            35.3

            47.1

            626.7

            47.4

            Cerro Soltero I

            -

            -

            53.5

            -

            53.5

            -

            Cerro Soltero II

            -

            -

            111.6

            -

            111.6

            -

            El Cerro

            -

            -

            37.6

            -

            37.6

            -

            Granitic aggregates:*

            La Preferida

            61.8

            -

            54.2

            -

            116

            -

    * The information (prices, costs and economic aspects) assumed for the Mineral Reserves estimation in the economic model can be found in the
        TRS set forth in Exhibits 96.1 to this annual report.

    * The Company use an average price of US$93 per tonne for the economic analysis. Further detail can be found in
        the Technical Report Summary (TRS) set forth in Exhibit 96.1

    ** Limestone is used for cement and lime production. 100% of the limestone received at the plant is used.

    Draft disclosure in response to comment 2.

    L’Amalí and Olavarría Cement Plant

      Right Image — Lower right margin: Latitude: 37° 3'12.12"S, Longitude: 60°14'58.06"W. Top
          left margin: Latitude: 36°58'42.59"S, Longitude: 60°19'58.69"W.

        5

        La Pampita y Entorno Mining Operations

      Right Image — Lower right margin: Latitude: 37° 4'52.25"S, Longitude: 60° 6'33.87"W. Top
          left margin: Latitude: 36°50'41.71"S, Longitude: 60°21'49.94"W.

      Draft disclosure in response to comment 3.

      Facilities

      The La Pampita y Entorno quarry has facilities such as offices, an electrical substation, a maintenance shop, a lubricant warehouse, a gas station, a oil tank, a guardhouse, a limestone field, a
        dining room, a laboratory, a truck scale, an ore belt, a loading tunnel, a meteorological station, a safety trench and a septic tank.

      The total cost of the mining concession, mine development costs, land, buildings and other facilities, machinery and
          equipment, furniture and fixtures, transportation units, computer equipment and tools, quarry rehabilitation costs, capitalized interest and work in progress amounts to as of December 31, 2021.

      The book value of L’Amalí and Olavarría cement plants and the La Pampita y Entorno quarry,
          taking into account all of the above factors, amounts to Ps. 59,186.85 million as of December 31, 2021.

        6

        Draft disclosure in response to comment 4.

        L’Amalí and Olavarría Cement Plant

          Right Image — Lower right margin: Latitude: 37° 3'12.12"S, Longitude: 60°14'58.06"W. Top left margin: Latitude: 36°58'42.59"S, Longitude: 60°19'58.69"W.

        La Pampita y Entorno Mining Operations

          Right Image — Lower right margin: Latitude: 37° 4'52.25"S, Longitude: 60° 6'33.87"W. Top left margin: Latitude: 36°50'41.71"S, Longitude: 60°21'49.94"W.

        7

        Draft disclosure in response to comment 5.

        Figure 11.2 Location of exploration drillings and cross section trace

        [References: highlighted in yellow the exploration drillings. The red line is the trace of the cross section]

          8

        Figure 11.3 Cross Section of the local geology

        Draft disclosure in response to comment 6.

        10.4 Opinion of Qualified Person on Adequacy of
            Test Data

        The QP, as part of Loma Negra’s geologist team, is satisfied
            with the preparation, review, issuance and control of test reports associated with cement production, and considers them to be reasonably valid. The QP’s opinion is that the test data that underlies assumptions about cement production in the
            associated test reports has been analyzed and collected appropriately and reasonably and is adequate to support the assumptions in this technical report.

        Draft disclosure in response to comment 7.

        10.2.Cement Manufacturing Test Results

        The studies conducted in the Quality Control and Process area include reduction of the clinker/cement factor. The clinker/cement factor cements were 0.87 in 2021 (mostly
          influenced for the OPC cement type production) for L'Amali plant. In the case of Olavarría Plantplant, the factor in 2021 was
          0.63. In the case of both L'Amali plant and Olavarría plant, due to the characteristics of the process, the rate of
              metallurgical recovery is 100%.

        12.3.2 Reasonable Prospects of Economic Extraction

        The mineral reserves evaluation has considered other modifying factors such as limestone production costs, cement sales prices, environmental and social viability at our
          operations. The price assumed for the mineral reserves evaluation is a price of 93 US dollars per ton of cement, averaged over
              a 63-year projection for the life of the quarry, at nominal values.

          9

          Draft disclosure in response to comment 8.

          13.6 Life of Mine

          A LOM (life of mine (“LOM”) of 134 years has been calculated for the quarry, based on the exploitation of the last five years (average 4.69 million tonnes per
                year). Considering the maximum capacity of the three plants supplied by the quarry (9.39 million tonnes per year), LOM would be 63 years.

          Draft disclosure in response to comment 9.

          Cement prices are strongly correlated with inflation and the variation in
                the exchange rate between the Argentine peso
                and the US dollar, as reflected by historical data for the five years.

          Figure 26 Cement Price, CPI and Ps./US$
              variations

                  *INDEC: Nation

                  **YoY variation of Loma Negra's Net Revenue of cement, masonry and lime/Sales Volume of Cement, masonry
                        and lime

                  ***Variation of the average exchange rate (Communication “A” 3500) reported by the Central Bank for U.S.
                        dollars

          Source: INDEC, BCRA and the Company

          Draft disclosure in response to comment 10.

          Considering that the quarry production and cement plants will
              continue in the same geological deposit and using the same mining and industrial methods, there is limited risk associated with the estimation methods used for capital and production costs. An assessment of accuracy of estimation methods is
              reflected in the sensitivity analysis in Section 19. Fo

United States securities and exchange commission logo
February 17, 2023
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Amendment No. 1 to Form 20-F for the Year Ended December 31, 2021
File No. 1-38262
Dear Marcos Gradin:
            We have reviewed your filing 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.
Amendment No. 1 to Form 20-F for the Year Ended December 31, 2021
Overview of Mineral Reserves, page 4
1.We reviewed your reserve disclosure and noted the sale price for your salable products,
which serve as a basis of your reserve determination, was not disclosed in your filing as
required the footnotes to Tables 1 and 2 of paragraph (b) for Item 1303 of Regulation S-
K.  In addition, the metallurgical recoveries were not disclosed for your material
properties as required by Items 1304(d)(1) of Regulation S-K.  Please modify your filing
and include these modification factors for each of your properties with your reserve tables.
Location and History, page 5
2.We note your individual material property disclosure beginning in this section.  Please
modify your filing and locate each of your material properties within one mile, using an
easily recognizable coordinate system to comply with Item 1304(b)(1)(i) of Regulation S-
K.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 February 17, 2023 Page 2
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
February 17, 2023
Page 2
Facilities, page 9
3.Please modify your filing and include the book value for your material property as
required by Item 1304(b)(2)(iii) of Regulation S-K.
Exhibit 96.1
La Pampita y Entorno Quarry, page 8
4.Please modify your filing to locate your property to within one-mile using an easily
recognizable coordinate system.  In addition, please enlarge your maps and illustrations to
make them legible as required by Item 601(B)(96)(iii)(b)(3)(i) of Regulation S-K.
Exhibit 96.1
Geological Units involved in the project, page 14
5.Please modify your filing to provide a cross-section of the local geology as required by
Item 601(B)(96)(iii)(b)(6)(iii) of Regulation S-K.
Exhibit 96.1
Adequacy of the Test Data, page 26
6.We reviewed the mineral processing section of your technical report summary.  Please
modify your filing to include the QP’s opinion on the adequacy of the data and state the
metallurgical recovery as required by Item 601(B)(96)(iii)(b)(10)(v) of Regulation S-K.
Exhibit 96.1
Reserves Estimation, page 30
7.We note you did not disclose a reserve price or metallurgical recovery for your reserve
estimates.  Please state the price and recovery used to determine your reserves and
disclose, with particularity, the reasons this price was selected and any assumptions
underlying this selection.  See Item 601(B)(96)(iii)(b)(12)(iii) of Regulation S-K.
Exhibit 96.1
Annual Production Rate, page 35
8.Please modify your technical report to provide the annual Life of Mine (LOM) production
schedule for your limestone and waste production as required by Item
601(B)(96)(iii)(b)(13) of Regulation S-K.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 February 17, 2023 Page 3
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
February 17, 2023
Page 3
Exhibit 96.1
Market Studies, page 40
9.We note you did not disclose a commodity price forecast in the section.  Please modify
your technical report to disclose your cement price projections and the basis for your
commodity price forecast as used in your economic evaluation as required by Item
601(B)(96)(iii)(b)(16) of Regulation S-K.
Exhibit 96.1 A
Capital and Operating Costs, page 43
10.We note you did not disclose an accuracy estimate with your capital and operating cost
estimates as required by Item 601(B)(96)(iii)(b)(18)(i) of Regulation S-K.  Please modify
your filing to include your accuracy estimate and discuss how the annual operating costs
in this section relate to the operating costs presented in the economic analysis.
Exhibit 96.1 A
Economic Viability, page 44
11.Please modify your technical report to include the annual mined material tonnage in your
cash flow analysis as required by Item 601(B)(96)(iii)(b)(19) of Regulation S-K.
            If you have questions regarding mining comments, please contact Ken Schuler, Mine
Engineer, at (202) 551-3718 or Craig Arakawa at (202) 551-3650. You may contact Mindy
Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
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    November 29, 2022

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street, N.E.

    Washington, D.C. 20549

    Attn:            Ken Schuler, Craig Arakawa, Mindy Hooker, Kevin Stertzel

      Re:              Loma Negra Compañía Industrial Argentina Sociedad Anónima Form 20-F for the year ended December 31, 2021 Filed April 29, 2022 File No. 1-38262

    Ladies and Gentlemen:

    Loma Negra Compañía Industrial Argentina Sociedad Anónima (the “Company”) is submitting this letter in response to the comment letter dated November 17, 2022 (the “Comment
          Letter”) issued by the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) with respect to the draft Form 20-F for the year ended December 31, 2021, confidentially submitted to the Commission on April 29, 2022 (the “Draft Form 20-F”).

    To facilitate the Staff’s review, the text set forth below in bold-faced type, immediately following the paragraph number, is a reproduction of
      the comment included in the Comment Letter. Capitalized terms used and not otherwise defined herein shall have the meanings set forth in the Draft Form 20-F.

    Form 20-F for the year ended December 31, 2021

    General

              1.

              We have read your response to comment one noting that you have re-assessed your conclusion on effectiveness of your disclosure
                controls and procedures and that you believe that they were effective as of December 31, 2021. We continue to consider the omitted disclosures and information required to comply with SK 1300 to be material and do not agree with your
                assessment. Please revise to state that your disclosures controls and procedures were not effective as of December 31, 2021 in your amended Form 20-F.

    As per the Staff’s request, the Company will re-conduct its assessment of disclosures controls and procedures and plans to file an amendment to
      its annual report on Form 20-F for the fiscal year ended December 31, 2021 stating that its disclosures controls and procedures were not effective as of December 31, 2021.

    * * *

    We appreciate in advance your time and attention to our responses.  Should you have any additional questions or concerns, please contact John Guzman of White &
      Case LLP at +55 11 3147 5607 or Scott Levi of White & Case LLP at +1 212 819 8320.

            Very truly yours,

            Marcos Gradin

            Chief Financial Officer

            Loma Negra Compañía Industrial Argentina Sociedad Anónima

    cc:            Sergio Damián Faifman

            Loma Negra Compañía Industrial Argentina Sociedad Anónima

      John Guzman, Esq.

      Scott Levi, Esq.

    White & Case LLP

  2

United States securities and exchange commission logo
November 17, 2022
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the Year Ended December 31, 2021
Response dated November 2, 2022
File No. 1-38262
Dear Marcos Gradin:
            We have reviewed your November 2, 2022 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
October 19, 2022 letter.
Form 20-F for the Year Ended December 31, 2021
General
1.We have read your response to comment one noting that you have re-assessed your
conclusion on effectiveness of your disclosure controls and procedures and that you
believe that they were effective as of December 31, 2021.   We continue to consider the
omitted disclosures and information required to comply with SK 1300 to be material and
do not agree with your assessment.  Please revise to state that your disclosures controls
and procedures were not effective as of December 31, 2021 in your amended Form 20-F.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 November 17, 2022 Page 2
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
November 17, 2022
Page 2
            If you have questions regarding mining comments, please contact Ken Schuler, Mine
Engineer at (202) 551-3718 or Craig Arakawa at (202) 551-3650. You may contact Mindy
Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    November 2, 2022

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street, N.E.

    Washington, D.C. 20549

    Attn:            Ken Schuler, Craig Arakawa, Mindy Hooker, Kevin Stertzel

          Re:

            Loma Negra Compañía Industrial Argentina Sociedad
                Anónima Form 20-F for the year ended

            December 31, 2021 Filed April 29, 2022 File No. 1-38262

    Ladies and Gentlemen:

    Loma Negra Compañía Industrial Argentina
        Sociedad Anónima (the “Company”) is submitting this letter in response to the comment letter dated July 28, 2022 (the “Comment Letter”) issued by the staff of the Division of Corporation Finance (the “Staff”) of the
      U.S. Securities and Exchange Commission (the “Commission”) with respect to the draft Form 20-F for the year ended December 31, 2021, confidentially submitted
      to the Commission on April 29, 2022 (the “Draft Form 20-F”).

    To facilitate the Staff’s review, the text set forth below in bold-faced type, immediately following each paragraph number, is a
      reproduction of the comments included in the Comment Letter. Except as otherwise indicated, all references to page numbers and captions (other than those in the Staff’s comments) correspond to the page numbers and captions in the copy of the
      Amendment. Capitalized terms used and not otherwise defined herein shall have the meanings set forth in the Amendment.

    Form 20-F for the year ended December 31, 2021

    General

              1.

              We note your response to our comment indicating you will prepare and file the appropriate technical reports
                and provide additional disclosures in your Form 20-F for the fiscal year ended December 31, 2022 to comply with Item 1300 of Regulation S-K. We believe that the omitted information is material, and that an amendment to your Form 20-F for
                fiscal year ended December 31, 2021 is appropriate. Additionally, in light of the omission of S-K 1300 disclosures and related technical reports, please reassess your conclusion that your disclosure controls and procedures were effective as
                of December 31,

    As per the Staff’s request, the Company is preparing and plans to file an amendment to its annual report on Form 20-F for the fiscal
      year ended December 31, 2021 (the “2021 Form 20-F”) to comply with Item 1300 of Regulation S-K.

    With respect to management’s assessment of disclosure controls and procedures as of December 31, 2021, the Company and its management
      take seriously their responsibility for the accuracy and the adequacy of the disclosure in the Company’s filings with the Commission. After further analysis in response to the Staff’s comment, the Company believes that its disclosure controls and
      procedures as of such date were effective under Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934, as amended (collectively, the “Disclosure Controls
          Rules”).

    The Disclosure Controls Rules define “disclosure controls and procedures” as “controls and other procedures of an issuer that are
      designed to ensure that information required to be disclosed by the issuer in the reports that it files or submits under the [Exchange] Act (15 U.S.C. 78a et seq.) is recorded, processed, summarized and reported, within the time periods specified in the [Commission’s] rules and forms.” As stated in the adopting release for the Disclosure Controls Rules, the evaluation looks at whether
      these controls and procedures provide “reasonable assurance” that the disclosure actions stated in the rule are accomplished. See Release No. 34-46427 (Aug.
      28, 2002), referred to herein as the “Disclosure Controls Adopting Release”). The SEC did not define “reasonable assurance” in the Disclosure Controls Adopting
      Release, yet it made clear in other related guidance that a “reasonable assurance” standard with respect to SEC disclosure does not anticipate that every required item of disclosure will be captured. Instead, the standard is a “high level of
      assurance” that would satisfy “prudent officials in the conduct of their own affairs” when disclosing information required by SEC rules and forms. See Release No. 34-55929 (June 20, 2007) (“‘reasonableness’ is not an ‘absolute standard of exactitude for corporate records”); Division of Corporation
      Finance: Financial Reporting Manual, Topic 4310.7 (“[w]hile ‘reasonable assurance’ is a high level of assurance, it does not mean absolute assurance. The term ‘reasonable
        assurance’ relates to similar language in the Foreign Corrupt Practices Act. 1934 Act Section 13(b)(7) defines ‘reasonable assurance’ as the degree of assurance that would satisfy prudent officials in the conduct of their own affairs”).

      The Company believes that, consistent with its conclusion in its 2021 Form 20-F, its disclosure controls and procedures were effective
        as of December 31, 2021 at the “reasonable assurance” level pursuant to the Disclosure Controls Rules, and that the omission of the required Regulation S-K 1300 data did not represent a sufficiently material error to change that analysis. The
        reasons for the Company’s view are twofold:

              ●

              The Company has, and had at
                  the time of the applicable evaluation of its disclosure controls and procedures, well-developed controls over mineral resources and reserves disclosures: The Company currently has, and as of December 31, 2021 had, well-developed
                controls in place to review annually the accuracy and completeness of disclosure on its mineral resources and reserves in its annual report on Form 20-F. The Company began implementing these controls when preparing for its initial public
                offering (“IPO”), when it tested whether its mineral resources and reserves were sufficiently “significant” as defined by then-effective Industry
                Guide 7 to trigger reporting thereunder in the Company’s registration statement on Form F-1. Based on the totality of information about its mining resources and reserves relative to its business and financial condition, the Company
                determined that the level of materiality of the Company’s mineral resources and reserves was too low to trigger Industry Guide 7 reporting. The Company has conducted the same analysis in each of the fiscal years since its IPO, ahead of
                filing its annual report on Form 20-F.. Thus, the Company applied these same controls for its annual report on Form 20-F for the fiscal year ended December 31, 2021.

              ●

              The mineral resources and
                  reserves disclosures in the 2021 Form 20-F derived from those controls are materially accurate and complete, and do not call into question the effectiveness of the controls: After re-reviewing the 2021 Form 20-F, the Company
                believes that its mineral resources and reserves disclosures in the 2021 Form 20-F were materially adequate, considering the total mix of information about the Company available to investors and the Regulation S-K 1300 requirements, and
                that the omission of Regulation S-K 1300 data was not sufficiently material to indicate ineffective controls and procedures over those disclosures at the “reasonable assurance” level. First, while the Company included ample disclosure on
                its mining reserves in its 2021 Form 20-F, it does not believe that certain granular information about the reserves is material to investors. As the Company assessed, as of December 31, 2021, the assets of total limestone reserves were less
                than 5% of total assets and the cost of limestone production, respectively. The Company’s limestone reserves have not, and had not as of December 31, 2021, changed materially since the IPO. As at the time of its IPO, the Company’s core
                business is manufacturing and distributing these finished products, and not the exploration, development or extraction of minerals. Second, the disclosures in the Annual Report on Form 20-F for the fiscal year ended December 31, 2021
                already include many of the disclosures required by Regulation S-K Item 1300, such that what is missing is immaterial. With respect to the summary property disclosure required by Regulation S-K Item 1303, the Company provides: a map of the
                location of all of its properties (p. 39, required by Item 1303(b)(1)); aggregate annual production data for 2021, with data on 2020 and 2019 available in prior annual reports on Form 20-F (p. 38, required by Item 1303(b)(2)); information
                on the location and stage of development, type and amount of ownership interests, mine type and  processing plants (p. 38-41, required by Item 1303(b)(2)); and summary data on proven and probable active mining rights (p. 38, required by
                Item 1303(b)(3)). With respect to individual property disclosure required by Regulation S-K Item 1304, the Company provides: data regarding the infrastructure surrounding its largest quarries at Olavarría and L’Amalí (p. 52-55, required by Item 1304(b)); and fiscal
                  year 2021 data on proven and probable mineral reserves for each of its quarries (p. 39, required by Item 1304(b) for any individual property triggering disclosure under that section). While the Company does not provide certain
                other data required by Regulation S-K Item 1304 for any single quarry due to its views on the materiality of single quarries to its total operations, it provides certain aspects of required individual property disclosure in the aggregate,
                including the mining method and processing operations (p. 32-37, required by Item 1304(b)). The Company acknowledges that does not include in
                  the 2021 Form 20-F a technical report required by Item 1302, certain mineral resources and other information required by Item 1303 and 1304, and mining-specific internal controls disclosure required by Item 1305. However, the Company does not believe that such additional information would have been sufficiently material to make the disclosure not misleading
                  or otherwise raise doubt about the effectiveness of the Company’s disclosure controls and procedures.

      Based on the foregoing, the Company respectfully submits to the Staff that it continues to conclude that its
        disclosure controls and procedures were effective as of December 31, 2021.

    * * *

    We appreciate in advance your time and attention to our responses.  Should you have any additional questions or concerns, please contact John Guzman of White
      & Case LLP at +55 11 3147-5607 or Scott Levi of White & Case LLP at +1 212 819 8320.

            Very truly yours,

            Marcos Gradin

            Chief Financial Officer

            Loma Negra Compañía Industrial Argentina Sociedad Anónima

    cc:            Sergio Damián Faifman

            Loma Negra Compañía Industrial Argentina Sociedad Anónima

    John Guzman, Esq.

    Scott Levi, Esq.

    White & Case LLP

United States securities and exchange commission logo
October 19, 2022
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the Year Ended December 31, 2021
Response dated September 1, 2022
File No. 1-38262
Dear Marcos Gradin:
            We have reviewed your September 1, 2022 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
August 18, 2022 letter.
Form 20-F for the Year Ended December 31, 2021
General
1.We note your response to our comment indicating you will prepare and file the
appropriate technical reports and provide additional disclosures in your Form 20-F for the
fiscal year ended December 31, 2022 to comply with Item 1300 of Regulation S-K.  We
believe that the omitted information is material, and that an amendment to your Form 20-F
for fiscal year ended December 31, 2021 is appropriate. Additionally, in light of the
omission of S-K 1300 disclosures and related technical reports, please reassess your
conclusion that your disclosure controls and procedures were effective as of December 31,
2021.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 October 19, 2022 Page 2
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
October 19, 2022
Page 2
            If you have questions regarding mining comments, please contact Ken Schuler, Mine
Engineer at (202) 551-3718 or Craig Arakawa at (202) 551-3650. You may contact Mindy
Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    September 1, 2022

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street, N.E.

    Washington, D.C. 20549

    Attn:            Ken Schuler, Craig Arakawa, Mindy Hooker and Kevin Stertzel

          Re:

            Loma Negra Compañía Industrial Argentina Sociedad
              Anónima Form 20-F for the year ended December 31, 2021 Filed April 29, 2022 File No. 1-38262

    Ladies and Gentlemen:

    Loma Negra Compañía Industrial
      Argentina Sociedad Anónima (the “Company”) is submitting
      this letter in response to the comment letter dated August 18, 2022 (the “Comment Letter”) issued by the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
      with respect to the Form 20-F for the year ended December 31, 2021, filed with the Commission on April 29, 2022 (the “Form 20-F”).

    Form 20-F for the year ended December 31, 2021

    Business Overview, page 31

              1.

              We note your response to comment 1, which included a materiality analysis concluding that you do not have
                material mining operations. Please confirm your valuation of the mining assets consisted of the quarry and all processing operations to the point of material external sales. This definition of mining assets for vertically integrated mining
                companies, became effective with S-K 1300. Mining assets would normally include the quarry, crushing/screening facilities, kiln, transportation, packaging, shipping and warehousing to the point of material external sales. Additional
                downstream facilities could be added depending on the extent of your vertical integration and dependence on your limestone/cement operations. See Item 1301 (c)(3) of Regulation S-K.

    We respectfully acknowledge the Staff’s comment.  Following the Company’s telephone conversations with the Staff on
      August 24, 2022 and August 31, 2022, the Company has re-evaluated the quantitative and qualitative materiality analysis of its mining operations, taking also into account the Staff’s position that the term ‘mining assets’ includes the quarry and all
      processing operations to the point of material external sales.  In light of the Mining Disclosure Rule Amendments resulting in the adoption of Item 1300 of Regulation S-K, and the Staff’s interpretation of the term ‘mining assets’, the Company has
      determined that its mining assets would be material for purposes of Item 1301(c) of Regulation S-K.

    The Company will take the actions necessary to prepare the disclosures required by the applicable subparts of Item 1300
      of Regulation S-K and respectfully requests to make such disclosures in its future annual report on Form 20-F for the fiscal year ended December 31, 2022.

    Mineral Reserves, page 38

              2.

              We note you do not report any measured, indicated or inferred mineral resources from which reserves are
                determined. Please explain.

    As discussed in the Company’s response to Comment No. 1, the Company intends to include the required disclosure under
      the applicable subparts of Item 1300 of Regulation S-K in its annual report on Form 20-F for the fiscal year ended December 31, 2022, with respect to the periods covered by that report.

    We would be pleased to discuss the Company’s responses to Comment No. 1 and Comment No. 2 above in order to provide additional
      context as needed.

    We appreciate in advance your time and attention to our responses.  Should you have any additional questions or concerns, please
      contact John Guzman of White & Case LLP at +55 11 3147-5607or Scott Levi of White & Case LLP at +1 212 819 8320.

            Very truly yours,

            Marcos Gradin

            Chief Financial Officer

              Loma Negra Compañía Industrial Argentina Sociedad

              Anónima

      cc:            Sergio Damián Faifman

      Loma Negra Compañía
        Industrial Argentina Sociedad Anónima

      John Guzman, Esq.

      Scott Levi, Esq.

      White & Case LLP

United States securities and exchange commission logo
August 18, 2022
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the year ended December 31, 2021
Filed April 29, 2022
File No. 1-38262
Dear Mr. Gradin:
            We have reviewed your August 11, 2022 response to our comment letter 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.  Unless we note otherwise, our references to prior comments are to comments in our
July 28, 2022 letter.
Form 20-F for the year ended December 31, 2021
Business Overview, page 31
1.We note your response to comment 1, which included a materiality analysis concluding
that you do not have material mining operations.  Please confirm your valuation of the
mining assets consisted of the quarry and all processing operations to the point of material
external sales.  This definition of mining assets for vertically integrated mining
companies, became effective with S-K 1300.  Mining assets would normally include the
quarry, crushing/screening facilities, kiln, transportation, packaging, shipping and
warehousing to the point of material external sales.  Additional downstream facilities
could be added depending on the extent of your vertical integration and dependence on
your limestone/cement operations.  See Item 1301 (c)(3) of Regulation S-K.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 August 18, 2022 Page 2
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
August 18, 2022
Page 2
Mineral Reserves, page 38
2.We note you do not report any measured, indicated or inferred mineral resources from
which reserves are determined.  Please explain.
            If you have questions regarding mining comments, please contact Ken Schuler, Mine
Engineer at (202) 551-3718 or Craig Arakawa at (202) 551-3650. You may contact Mindy
Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

CORRESP
1
filename1.htm

    August 11, 2022

    U.S. Securities and Exchange Commission

    Division of Corporation Finance

    Office of Manufacturing

    100 F Street, N.E.

    Washington, D.C. 20549

    Attn:            Ken Schuler, Craig Arakawa, Mindy
        Hooker and Kevin Stertzel

          Re:

            Loma Negra Compañía Industrial Argentina Sociedad Anónima Form 20-F for the year ended December 31,
              2021 Filed April 29, 2022 File No. 1-38262

    Ladies and Gentlemen:

    Loma Negra Compañía Industrial Argentina Sociedad Anónima (the “Company”) is
      submitting this letter in response to the comment letter dated July 28, 2022 (the “Comment Letter”) issued by the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
      with respect to the Form 20-F for the year ended December 31, 2021, filed with the Commission on April 29, 2022 (the “Form 20-F”).

    The Company intends to update its future Form 20-F filing in response to Comment No. 4 and Comment No. 5 below.  We would be pleased to discuss the Company’s
      responses to Comment No. 1, Comment No. 2 and Comment No. 3 below.

    Form 20-F for the year ended December 31, 2021

    Item 4. Information on the Company

    Business Overview, page 31

              1.

              We note you own significant limestone reserves supporting your vertically-integrated concrete and cement business. Please file
                technical report summaries for your material resource/reserve properties that conforms to Item 601(b)(96) of Regulation S-K as required by Item 1302(b).

    In response to the Staff’s comment, the Company respectfully informs the Staff that it has assessed the materiality of its mining operations as
      required by Item 1301 of Regulation S-K, using the factors set forth in Release No. 34-84509 (Oct. 31, 2018). Based on this analysis, the Company understands that its mining operations are not material for purposes of filing technical report
      summaries as required by Item 1302(b) of Regulation S-K. In particular, the Company has measured the materiality of its mining operations using both qualitative and quantitative factors, evaluated in the context of the Company’s overall business and
      financial condition, including the aggregate mining operations of all the Company’s mining properties and the size and type of commodity produced.

    In addition, the Company respectfully informs the Staff that it conducted the same analysis while preparing for its initial public
        offering (the “IPO”) in 2017. At that time, disclosures by registrants with mining operations were governed by now-rescinded Industry Guide 7, which required specialized reporting by registrants with “significant” mining operations. In a 2017
        telephone conversation with the Staff prior to the IPO, the Company conveyed, and the Staff concurred with the Company regarding, the Company’s reasons for its conclusion that its mining operations were not sufficiently “significant” to trigger
        Industry Guide 7 reporting. While Industry Guide 7 has since been replaced by new Item 1300 of Regulation S-K and certain other amended rules  (the “Mining Disclosure Rule Amendments”), which added certain new requirements (including the Item
        1302(b) technical report), the SEC has stated that the analysis of whether a registrant’s mining operations are sufficiently “significant” to give rise to specialized reporting did not fundamentally change under the Mining Disclosure Rule
        Amendments. Instead, the Mining Disclosure Rule Amendments reworded the standard from “significant” mining operations to “material” mining operations, codifying the SEC’s position that the Industry Guide 7 “significance” analysis turned on whether
        a registrant’s mining operations were “material” as that term is understood throughout the U.S. securities laws and SEC rules. As stated in the adopting release for the Mining Disclosure Rule Amendments, “the staff historically has advised
      registrants to apply a materiality standard in determining what disclosures to provide.” In the same adopting release, the SEC also stated that “the staff…has used 10% of a
      registrant’s total assets as the benchmark for determining the materiality of a registrant’s mining operations,” although it determined not to codify this as a bright-line threshold in the Mining Disclosure Rule
      Amendments.

    The factors listed below underpin the Company’s determination currently that its mining operations are not “material” within the meaning of Item
      1301 of Regulation S-K, consistent with its view at the time of the IPO that such operations were not “significant” within the meaning of Industry Guide 7.

              •

              The Company is, and historically has been, dedicated to the production and distribution of cement, masonry cement, aggregates, concrete and lime, which
                are products used in private and public construction. Although the Company is vertically integrated and is supported by its own limestone reserves, the Company’s core business is manufacturing and distributing these finished products, and
                not the exploration, development or extraction of minerals.

              •

              The cost of limestone production as a percentage of total cost of sales is immaterial. For the years ended December 31, 2021 and 2016, it represented
                only 4.4% and 4.5%, respectively.

              •

              The Company currently owns and operates six open-pit quarries in Argentina from which limestone can be extracted. At the time of the IPO, the Company
                also owned and operated an additional limestone quarry in Paraguay. For the years ended December 31, 2021 and 2016, mostly all of the Company’s limestone was sourced from its own quarries. As of December 31, 2021 and 2016, the book value of
                the assets of these total limestone reserves was not material, representing less than 5% of total assets. Specifically, as of December 31, 2021, assets of total limestone reserves represented ARS$5.0 billion, or 4.8% of the Company’s total
                consolidated assets of the Company, which were ARS$104.9 billion, and as of December 31, 2016, assets of total limestone reserves represented ARS$0.4 billion, or 4.8% of the Company’s total consolidated assets of the Company, which were
                ARS$9.0 billion, respectively.

              •

              As of December 31, 2021 and 2016, the Company’s total limestone reserves were 1,091 million tons and 852.9 million tons, respectively. While limestone
                reserves have grown over time, the growth has been consistent with that of the Company’s installed cement capacity and installed clinker capacity, which were 12.3 million tons and 7.3 million tons for the year ended December 31, 2021,
                compared to 9.9 million and 5.5 million tons for the year ended December 31, 2016. Additionally, the Company’s annualized limestone production has not materially changed since the IPO, and, in fact, has decreased slightly from 2016 to 2021.
                For the years ended December 31, 2021 and 2016, the Company’s total annualized limestone production at the Company’s quarries was 7.8 million tons and 8.3 million tons, respectively. The Company does not resell any of its excess produced
                limestone to third parties.

    As detailed above, through quantitative and qualitative information, the Company’s mineral assets are used mainly as a source of raw material
      for its process of cement production and its mining operations are not sufficiently “material” under Item 1301 of Regulation S-K to trigger the requirement for a technical report under Item 1302(b).

    Our Production Facilities, page 49

              2.

              We note your production facility overview in this section. Summary disclosure includes the separate disclosure of all properties,
                which includes both your material and non¬material properties pursuant to Item 1303(a) of Regulation S-K. Please revise this section of your filing to include all the required information under Item 1303(b) of Regulation S- K for all your
                properties.

    Item 1303(b) of Regulation S-K only applies to the extent that a registrant has material mining operations. The Company respectfully advises the
      Staff that it does not believe Item 1303(b) applies to it because it does not have material mining operations, as determined in response to Comment No. 1 above.

    Investments, page 54

              3.

              We note your individual property disclosure for your material properties is missing from your filing. Please modify your filing to
                comply with See Item 1304(b) of Regulation S- K.

    Item 1304(b) of Regulation S-K only applies to the extent that a registrant has at least one material mining operation. The Company respectfully
      advises the Staff that it does not believe Item 1304(b) applies to it because it does not have material mining operations, as determined in response to Comment No. 1 above.

    Item 5. Operating and Financial Review and Prospects

    A. Operating Results

    Results of Operations, page 74

              4.

              Given the significance of energy costs on your results of operation, please revise future disclosures to quantify the impact that
                fluctuating energy costs had on your cost of sales separately from the volume impacts. Additionally, to the extent that you experience materially fluctuating freight costs, please enhance future disclosures to provide information to allow a
                reader to understand the impact changes in freight costs had versus increased volumes.

    In response to the Staff’s comment, in future filings the Company will quantify the impact that fluctuating energy costs had on the Company’s
      cost of sales. In addition, to the extent material, the Company will include disclosure on the impact fluctuating freight costs had on the Company’s cost of sales.

    D. Trend Information, page 86

              5.

              Your risk factor disclosure on page 15 discusses the expectation of higher energy and freight prices and the potential for energy
                shortages. In future filings, please discuss whether these concerns materially affect your outlook or business goals. Specify whether these challenges have materially impacted your results of operations or capital resources and quantify, to
                the extent possible, how your sales, profits, and/or liquidity have been impacted. Please discuss known trends or uncertainties resulting from mitigation efforts undertaken, if any. Finally, please explain whether any mitigation efforts
                introduce new material risks, including those related to product quality, reliability, or regulatory approval of products.

    In response to the Staff’s comment, in future filings the Company will include risk factor disclosure discussing the potential impact of higher
      energy and freight prices, as well as energy shortages on its outlook and business goals.  Further, the Company will specify whether these factors have materially impacted its results of operations, specifically with respect to revenue and liquidity.

    Because the Company does not currently expect these factors to have a material impact on its results of operations, the Company has not
      undertaken any mitigation efforts.  If the Company commences any mitigation efforts, it will identify such efforts in its subsequent filings.

    * * *

    We appreciate in advance your time and attention to our responses.  Should you have any additional questions or concerns, please contact John Guzman of White & Case LLP at +55 11 3147-5607or Scott
      Levi of White & Case LLP at +1 212 819 8320.

    Very truly yours,

    /s/  Marcos I. Gradin

    Marcos Gradin

    Chief Financial Officer

    Loma Negra Compañía Industrial Argentina Sociedad Anónima

    cc:            Sergio Damián Faifman

    Loma Negra Compañía Industrial Argentina Sociedad Anónima

    John Guzman, Esq.

    Scott Levi, Esq.

    White & Case LLP

United States securities and exchange commission logo
July 28, 2022
Marcos Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355 , 4th Floor
Zip Code C1107CPG – Ciudad Autónoma de Buenos Aires
Republic of Argentina
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the year ended December 31, 2021
Filed April 29, 2022
File No. 1-38262
Dear Mr. Gradin:
            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.
Form 20-F for the year ended December 31, 2021
Item 4. Information on the Company
Business Overview, page 31
1.We note you own significant limestone reserves supporting your vertically-integrated
concrete and cement business.  Please file technical report summaries for your material
resource/reserve properties that conforms to Item 601(b)(96) of Regulation S-K as
required by Item 1302(b).

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 July 28, 2022 Page 2
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
July 28, 2022
Page 2
Our Production Facilities, page 49
2.We note your production facility overview in this section.  Summary disclosure includes
the separate disclosure of all properties, which includes both your material and non-
material properties pursuant to Item 1303(a) of Regulation S-K.  Please revise this section
of your filing to include all the required information under Item 1303(b) of Regulation S-
K for all your properties.
Investments, page 54
3.We note your individual property disclosure for your material properties is missing from
your filing.  Please modify your filing to comply with See Item 1304(b) of Regulation S-
K.
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Results of Operations, page 74
4.Given the significance of energy costs on your results of operation, please revise future
disclosures to quantify the impact that fluctuating energy costs had on your cost of sales
separately from the volume impacts.  Additionally, to the extent that you experience
materially fluctuating freight costs, please enhance future disclosures to provide
information to allow a reader to understand the impact changes in freight costs had versus
increased volumes.
D. Trend Information, page 86
5.Your risk factor disclosure on page 15 discusses the expectation of higher energy and
freight prices and the potential for energy shortages.  In future filings, please discuss
whether these concerns materially affect your outlook or business goals. Specify whether
these challenges have materially impacted your results of operations or capital resources
and quantify, to the extent possible, how your sales, profits, and/or liquidity have been
impacted.  Please discuss known trends or uncertainties resulting from mitigation efforts
undertaken, if any. Finally, please explain whether any mitigation efforts introduce new
material risks, including those related to product quality, reliability, or regulatory approval
of products.

            In closing, 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.

 FirstName LastNameMarcos Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 July 28, 2022 Page 3
 FirstName LastName
Marcos Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
July 28, 2022
Page 3
            If you have questions regarding mining comments, please contact Ken Schuler, Mine
Engineer at (202) 551-3718 or Craig Arakawa at (202) 551-3650.  You may contact Mindy
Hooker at (202) 551-3732 or Kevin Stertzel at (202) 551-3723 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing

September 24, 2019
Marcos Isabelino Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355, 4th Floor
Ciudad Autónoma de Buenos Aires Argentina
C1107CPG
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the year ended December 31, 2018
Filed April 30, 2019
File No. 001-38262
Dear Mr. Gradin:
            We have completed our review of your filing.  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.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
filename1.htm

              Cecilia Grierson 355 4° piso | Puerto Madero

              C1107 CPG – Cdad. Autónoma de Bs. As.

              Tel +54 11 4319-3000

              www.lomanegra.com.ar

    September 23, 2019

    Securities and Exchange Commission

    Division of Corporate Finance

    Office of Manufacturing and Construction

    100 F Street, N.E.

    Washington, D.C. 20549

    Re: Loma Negra Compañía Industrial Argentina Sociedad Anónima.

    Form 20-F for the fiscal year ended December 31, 2018.

    Filed April 30, 2019.

    File No. 001-38262.

    Dear Sirs,

    This letter sets forth Loma Negra Compañía Industrial Argentina Sociedad Anónima’s responses to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange
      Commission contained in the Staff’s letter dated August 14, 2019 (the “Comment Letter”).

    For the Staff’s convenience, the Staff’s comments have been stated below in their entirety, with the responses to a particular comment
      set out immediately under the comment or comments. The headings and numbered paragraphs in this letter correspond to the headings and numbered paragraphs in the Comment Letter from the Staff.

    Form 20-F for the year ended December 31, 2018

    Item 15. Controls and Procedures

    Management’s annual report on internal control over financial reporting, page 139

    1. We note your disclosure that this annual report does not include a report of management’s assessment regarding internal control over
      financial reporting due to a transition period established by rules of the Securities and Exchange Commission for newly public companies. The instructions to Item 15 of Form 20-F provide a transition period until you have filed an annual report with
      the commission for the prior year. Subsequent to the effectiveness of your Form F-1 on October 31, 2017, you filed your first annual report under Form 20-F for the period ended December 31, 2017 on April 27, 2018. Please advise or amend your Form
      20-F to include management’s assessment on internal controls over financial reporting for the fiscal year ended December 31, 2018

                Cecilia Grierson 355 4° piso | Puerto Madero

                C1107 CPG – Cdad. Autónoma de Bs. As.

                Tel +54 11 4319-3000

                www.lomanegra.com.ar

    Response:

    In response to the Staff’s comment, the Company clarifies that (i) management’s assessment on internal control over financial reporting
      for the fiscal year ended December 31, 2018, was concluded as of the date of our 20-F filing, and (ii) it unintentionally omitted the disclosure.  That disclosure should have included the following wording:

    “Our management is responsible for establishing and maintaining adequate internal control over financial reporting as
      defined in Rules 13a-15(f) and 15d-15(f) under the Securities Exchange Act of 1934. The company’s internal control over financial reporting was designed to provide reasonable assurance regarding the reliability of financial reporting and the
      preparation of financial statements for external purposes in accordance with IFRS. The company’s internal control over financial reporting includes those policies and procedures that:

              (i)

              pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets
                of the company;

              (ii)

              provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with IFRS,
                and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and

              (iii)

              provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of the company’s assets
                that could have a material effect on the financial statements.

    Because of its inherent limitations, internal control over financial reporting may not prevent or detect
      misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may
      deteriorate.

    Management assessed the effectiveness of the company’s internal control over financial reporting as of December 31,
      2018. In making this assessment, management used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control-Integrated Framework (2013). Based on our assessment and those criteria, management
      believes that the company maintained effective internal control over financial reporting as of December 31, 2018.”

      The Company will file Amendment No. 1 to Form F-20 (the “Amendment”)

        for the year ended December 31, 2018 via the EDGAR system of the Securities and Exchange Commission.  In addition, the Company will file updated Section 302 certifications signed by its chief executive officer and chief financial officer,
        respectively. In accordance with Question 161.01 of the Compliance and Disclosure Interpretations of the Exchange Act Rules, paragraph 3 can be omitted from the Section 302 certifications because there are no financial statements or other financial
        information contained in the Amendment.

                  Cecilia Grierson 355 4° piso | Puerto Madero

                  C1107 CPG – Cdad. Autónoma de Bs. As.

                  Tel +54 11 4319-3000

                  www.lomanegra.com.ar

    Notes to the Consolidated Financial Statements

    2. Bases of Preparation of the Consolidated Financial Statements

    Impact of the initial application of IFRS 15 Revenue from Contracts with Customers, page F-11

    2. Your disclosures indicate that you applied IFRS 15 in the current year and that the application of IFRS 15 did not have a material
      impact on the Group's consolidated financial statements. Please revise future disclosures to comply with the disclosure requirements of IFRS 15, to enable users to understand the nature, timing and uncertainty of revenue and cash flows arising from
      contracts with customers. Additionally, please update your critical accounting policy for revenue recognition to reflect the new standard and any material estimates related to revenue recognition.

    Response:

    In response to the Staff’s comment, the Company acknowledges and respectfully informs the Staff that, in future filings, the Company
      expects to update the current disclosure and include the following disclosure in the section entitled “Critical Accounting Policies” or other similar section (as applicable) to our 20-F and Note 3.1 “Revenue recognition” to our consolidated financial
      statements:

              •

              Sales of goods

    Revenue from the sale of the Company’s products is recognized when delivery has taken place and control of the goods has been
      transferred to customers. The customer obtains control of the goods when the significant risks and rewards of products sold are transferred according to the specific delivery terms that have been agreed with the customer. Revenue from sales is
      recognized based on the price specified on the invoice, net of discounts. No element of financing is deemed present as the sales are made with credit terms averaging less than 30 days depending on the specific terms agreed to with the Company, which
      is consistent with market practice. Generally, cement, aggregates and ready-mix concrete are not returned as a customer will only accept these products once they have passed a stringent quality check at delivery point.

              •

              Services rendered

    Revenue from transportation services is recognized at the time the service is provided. The revenue is measured on the basis of the
      consideration defined in the contract with a customer.

    While the Company believes that the disclosure contained in the Company’s Form 20-F for the year ended December 31, 2018 are sufficient to enable readers
      to understand the nature, timing and uncertainty of revenue and cash flows in connection with the Company’s contracts with customers, the Company hereby informs the Staff that, for purposes of the Company’s on-going commitment to enhancing its
      disclosure, it will include more detailed information about the relationship between the disclosure of disaggregated revenue and revenue information disclosed for each reportable segment in its annual financial statements to be filed with the Form
      20-F for the year ended December 31, 2019.

    In addition, the Company respectfully advises to the Staff that there are no material estimates related to revenue recognition.

                  Cecilia Grierson 355 4° piso | Puerto Madero

                  C1107 CPG – Cdad. Autónoma de Bs. As.

                  Tel +54 11 4319-3000

                  www.lomanegra.com.ar

    24. Reserves and Accumulated Other Comprehensive Income, page F-48

    3. We note that you recorded a Facultative reserve within equity for future planned capital expenditures and other investment. Please
      tell us whether you have contracts in place for such expenditures or investments, and if so, your consideration for recording the reserves as liabilities at year end. Further, in future filings, please enhance your disclosures to discuss the capital
      expenditures and investments you are planning as part of your basis for the reserve.

    Response:

    The Company respectfully advises the Staff that:

              a)

              at the Company’s shareholders’ meeting held on April 25, 2018, the Company approved the allocation of its net profit for the year ended December
                31, 2017 in a facultative reserve.  Based on current regulations in Argentina, once approved, the shareholders’ meeting must allocate 100% of the Company’s net profit. Accordingly, and due to the plans of the Company related to the
                construction of a new cement plant, the Company’s shareholders decided not to distribute dividends; and

              b)

              as of the date hereof, all the expenditures already incurred and the Company’s contracts in place for such constructions, as well as all related
                liabilities, have been recorded in the Company’s consolidated financial statements at year end in accordance with IFRS.

    The Company confirms that it intends to revise its disclosures in future filings.

    Sincerely,

    __________________________________

    Name: Marcos I. Gradin

    Title: Chief Financial Officer

August 14, 2019
Marcos Isabelino Gradin
Chief Financial Officer
Loma Negra Compania Industrial Argentina Sociedad Anonima
Cecilia Grierson 355, 4th Floor
Ciudad Autónoma de Buenos Aires Argentina
C1107CPG
Re:Loma Negra Compania Industrial Argentina Sociedad Anonima
Form 20-F for the year ended December 31, 2018
Filed April 30, 2019
File No. 001-38262
Dear Mr. Gradin:
            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.
Form 20-F for the year ended December 31, 2018
Item 15. Controls and Procedures
Management’s annual report on internal control over financial reporting, page 139
1.We note your disclosure that this annual report does not include a report of management’s
assessment regarding internal control over financial reporting due to a transition period
established by rules of the Securities and Exchange Commission for newly public
companies. The instructions to Item 15 of Form 20-F provide a transition period until you
have filed an annual report with the commission for the prior year. Subsequent to the
effectiveness of your Form F-1 on October 31, 2017, you filed your first annual report
under Form 20-F for the period ended December 31, 2017 on April 27, 2018. Please
advise or amend your Form 20-F to include management’s assessment on internal controls
over financial reporting for the fiscal year ended December 31, 2018.

 FirstName LastNameMarcos Isabelino Gradin
 Comapany NameLoma Negra Compania Industrial Argentina Sociedad Anonima
 August 14, 2019 Page 2
 FirstName LastName
Marcos Isabelino Gradin
Loma Negra Compania Industrial Argentina Sociedad Anonima
August 14, 2019
Page 2
Notes to the Consolidated Financial Statements
2. Basis of Preparation of the Consolidated Financial Statements
Impact of the initial application of IFRS 15 Revenue from Contracts with Customers, page F-11
2.Your disclosures indicate that you applied IFRS 15 in the current year and that the
application of IFRS 15 did not have a material impact on the Group's consolidated
financial statements.  Please revise future disclosures to comply with the disclosure
requirements of IFRS 15, to enable users to understand the nature, timing and uncertainty
of revenue and cash flows arising from contracts with customers..  Additionally, please
update your critical accounting policy for revenue recognition to reflect the new standard
and any material estimates related to revenue recognition.
24. Reserves and Accumulated Other Comprehensive Income, page F-48
3.We note that you recorded a Facultative reserve within equity for future planned capital
expenditures and other investment.  Please tell us whether you have contracts in place for
such expenditures or investments, and if so, your consideration for recording the reserves
as liabilities at year end.  Further, in future filings, please enhance your disclosures to
discuss the capital expenditures and investments you are planning as part of your basis for
the reserve.
            In closing, 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.
            You may contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at 202-551-3723 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing and
Construction

CORRESP
1
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Acceleration Request

 Banco Bradesco BBI S.A.

Avenida Brigadeiro Faria Lima 3064

São Paulo, SP 01451-000, Brazil

Citigroup Global Markets Inc.

 388
Greenwich Street

 New York, New York 10013

HSBC Securities (USA) Inc.

 452
Fifth Avenue

 New York, New York 10018

Itau BBA USA Securities, Inc.

 767
Fifth Avenue, 50th floor,

 New York, New York 10153

Merrill Lynch, Pierce, Fenner & Smith

Incorporated

 One Bryant Park

New York, New York 10036

 Morgan
Stanley & Co. LLC

 1585 Broadway

New York, New York 10036

October 27, 2017

 Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:

Loma Negra Compañía Industrial Argentina Sociedad Anónima
CIK No. 0001711375
Registration Statement on Form F-1 (File No. 333-220347)
Request for
Acceleration of Effective Date

 Ladies and Gentlemen:

Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), we, as
representatives of the several Underwriters, wish to advise you that approximately 509 copies of the Preliminary Prospectus issued on October 12, 2017 and included in the Registration Statement on Form
F-1, as filed on September 5, 2017 and as amended, were distributed during the period from October 12, 2017 through the date hereof to prospective underwriters, dealers, institutions and others.

Securities and Exchange Commission

2

October 27, 2017

 The undersigned advise that they have complied and will continue to comply, and that they have been informed
by the other participating underwriters that they have complied and will continue to comply, with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934.

In accordance with Rule 461 of the Act, we hereby join in the request of Loma Negra Compañía Industrial Argentina Sociedad
Anónima for acceleration of the effective date of the above-named Registration Statement so that it becomes effective at 2:00 p.m. Eastern Time on October 31, 2017, or as soon thereafter as practicable.

[Remainder of page intentionally left blank]

 Very truly yours,

 BANCO BRADESCO BBI S.A.

CITIGROUP GLOBAL MARKETS INC.

HSBC SECURITIES (USA) INC.

ITAU BBA USA SECURITIES, INC.

MERRILL LYNCH, PIERCE, FENNER & SMITH

INCORPORATED

 MORGAN STANLEY & CO.
LLC

 Acting severally on behalf of themselves and the

several Underwriters

 BANCO BRADESCO BBI S.A.

 By:

 /s/ Glenn Mallett

 Name: Glenn Mallett

 Title:   Managing Director

 By:

 /s/ Paulo Francisco Laranjeira Jr.

 Name: Paulo Francisco Laranjeira Jr.

 Title:   Superintendente

 CITIGROUP GLOBAL MARKETS INC.

 By:

 /s/ Juan Carlos George

 Name: Juan Carlos George

 Title:   Managing Director

 HSBC SECURITIES (USA) INC.

 By:

 /s/ Alfred Traboulsi

 Name: Alfred Traboulsi

 Title:   Managing Director

ITAU BBA USA SECURITIES, INC.

By:

 /s/ Roderick Greenlees

Name:

Roderick Greenlees

Title:

Diretor Executivo

By:

 /s/ Pedro Garcia de Souza

Name:

Pedro Garcia de Souza

Title:

Managing Director

 MERRILL LYNCH, PIERCE, FENNER &

SMITH INCORPORATED

By:

 /s/ Michele A.H. Allong

Name:

Michele A.H. Allong

Title:

Authorized Signatory

MORGAN STANLEY & CO. LLC

By:

 /s/ Anna Malik

Name:

Anna Malik

Title:

Vice President

CORRESP
1
filename1.htm

Acceleration Request

 October 27, 2017

VIA EDGAR

 Pamela A. Long

Office of Manufacturing and Construction

 Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:
REQUEST FOR ACCELERATION OF EFFECTIVENESS

 Loma Negra Compañía
Industrial Argentina Sociedad Anónima

 CIK No. 0001711375

Registration Statement on Form F-1 (File
No. 333-220347)

 Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Loma Negra Compañía Industrial Argentina Sociedad
Anónima (the “Company”) hereby requests acceleration of the effective date of its Registration Statement on Form F-1 (File No. 333-220347),
as amended, to 2:00 p.m., Eastern Time, on Tuesday, October 31, 2017, or as soon thereafter as practicable.

 The Company hereby
acknowledges that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the
disclosure in the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Should you have any questions regarding this letter, please do not hesitate to contact John Vetterli at (212) 819-8816 or John Guzman at +55 (11) 3147-5607 of White & Case LLP, counsel to the Company.

[Remainder of Page Intentionally Blank]

Sincerely,

Loma Negra Compañía Industrial Argentina Sociedad Anónima

By

 /s/ Sergio D. Faifman

Name:

Sergio D. Faifman

Title:

Chief Executive Officer and Vice-President of the Board

By

 /s/ Marcos I. Gradin

Name:

Marcos I. Gradin

Title:

Chief Financial Officer

CORRESP
1
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SEC Response Letter

 October 19, 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

Amendment No. 2 to Registration Statement on Form F-1

Filed on October 12, 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 respond in this letter to the comments of the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the
“Commission”) contained in the Staff’s letter dated October 17, 2017 (the “Comment Letter”). The Staff’s Comment Letter relates to Amendment No. 2 (“Amendment
No. 2”) to the above-referenced registration statement on Form F-1 (the “Registration Statement”), which was filed with the Commission on October 12, 2017 via
the Commission’s EDGAR system. The Registration Statement was initially submitted confidentially to the Commission on July 12, 2017, filed on September 5, 2017, Amendment No. 1 thereto was filed on September 27, 2017 and
Amendment No. 3 thereto was filed on the date hereof solely for the purpose of filing an amendment to Exhibit 5.1.

 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. 2. Capitalized terms used but not defined herein have the meanings ascribed to such terms in Amendment
No. 2.

 Securities and Exchange Commission

October 19, 2017

 General

1.
Please note that your preliminary prospectus must include a bona fide price range. In general, we believe that a bona fide price range means a range of no more than 20% for offerings of greater than $10 per share.

 Response:

 In
response to the Staff’s comment, the Company respectfully clarifies to the Staff that the price range included in the preliminary prospectus is a bona fide price range pursuant to Item 501(b)(3) of Regulation
S-K because the price range per ordinary share offered is between US$3.00 and US$3.80.

 Voting Rights, page
207

2.
We reissue the first bullet of comment 1. Please make clear any timelines by which you will endeavor to provide notice to the depositary. We note paragraphs 2.10 and 5.6 of Exhibit 4.1.

Response:

 The Company acknowledges the
Staff’s comment and will revise the disclosure on page 207 of the section “Description of American Depositary Shares—Voting Rights” to clarify that the Company, in accordance with Section 4.10 of the Deposit Agreement filed
as Exhibit 4.1 to Amendment No. 2, intends to give notice of shareholders’ meetings to the depositary bank in writing together with voting materials at least 30 days in advance of the applicable shareholders’ meeting so that the
distribution of notices and voting materials to holders of ADSs can coincide with the publication of the corresponding notices to shareholders in Argentina.

The Company respectfully advises the Staff that this change will be reflected in the final prospectus that will be filed with the Commission
pursuant to Rule 424 under the Securities Act of 1933, no later than the second business day after the Registration Statement has been declared effective by the Commission.

Exhibit 5.1

3.
Please have counsel revise or remove the assumption (g) in paragraph three of its opinion.

Response:

 The Company acknowledges the
Staff’s comment and Argentine counsel has revised its legal opinion to remove the assumption (g) in paragraph three.

 * * *

Please do not hesitate to contact John Vetterli at (212) 819-8816 or John Guzman at +55 (11) 3147-5607
of White & Case LLP with any questions or comments regarding this letter.

 Sincerely,

/s/ White & Case LLP

cc:
Marcos Gradin, Chief Financial Officer, Loma Negra Compañía Industrial Sociedad Anónima

Mail Stop 4631

October 17, 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
Amendment No. 2  to Re gistration Statement on Form F -1
Filed October 12, 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 statement a nd 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 October 6, 2017  letter .

General

1. Please note that your preliminary prospectus  must include a bona fide price range.   In
general, we believe that a bona fide price range means a range of no more than 20% for
offerings of greater than $10 per share.

Voting Rights, page 207

2. We reissue the first bullet of comment 1.  Please make clea r any timelines by which you
will endeavor to provide notice to the depositary.  We note paragraphs 2.10 and 5.6 of
Exhibit 4.1.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
October 17, 2017
Page 2

 Exhibit 5.1

3. Please  have cou nsel revise or remove the assumption (g) in paragraph three  of its
opinion .

You may  contact  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,

 /s/ Asia Timmons -Pierce, for

Pamela A. Long
Assistant Director
Office of Manufacturing and
Construction

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

CORRESP
1
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SEC Response Letter

 October 12, 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

Amendment No. 1 to Registration Statement on Form F-1

Filed on September 27, 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. 2 (“Amendment No. 2”) 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, filed on September 5, 2017 and Amendment No. 1 thereto was filed on September 27, 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 October 6, 2017 (the “Comment Letter”).

We are providing by overnight delivery a courtesy package that includes four copies of Amendment No. 2, two of which have been marked to
reflect revisions from Amendment No. 1 to the Registration Statement filed on September 27, 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. 2. Capitalized terms used but not defined herein have the meanings ascribed to such terms in Amendment
No. 2.

 Description of American Depositary Shares, page 201

1.
We note your new disclosure under this heading and have the following comments:

 Securities and Exchange Commission

October 12, 2017

•

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.

 Response:

In response to the Staff’s comment, the Company has revised the disclosure as follows:

•

On page 50, the Company has clarified that the cut-off time for voting instructions from ADS holders to provide voting instructions to the depositary bank is typically up to two
business days prior to the cut-off date to vote shares in Argentina so as to enable the depositary bank to tally the ADS voting instructions received from ADS holders and to provide the corresponding voting
instructions at the share level in Argentina through the custodian of the ordinary shares represented by ADS. The Company has also modified the disclosure on page 207 to further explain that holders of ADSs shall provide voting instructions to the
depositary bank before the voting instruction cut-off date specified by the depositary bank in each case.

•

On page 211, the Company has modified the disclosure regarding pre-release transactions to further clarify that the deposit agreement limits the aggregate size of pre-release transactions to 30% of the ADSs outstanding (without taking into account pre-released ADSs).

Financial Statements, 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 concession, 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 continues 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.

 Response:

 The
Company respectfully advises the Staff that the concession of Ferrosur Roca S.A. (“Ferrosur”) is outside the scope of IFRIC 12 since it does not meet conditions in section a) of paragraph 5 of such

 2

 Securities and Exchange Commission

October 12, 2017

interpretation, which paragraph states that a service concession arrangement will be within its scope if both of these two conditions are met:

a)
the grantor controls or regulates what services the operator must provide with the infrastructure, to whom it must provide them, and at what price;
and

b)
the grantor controls – through ownership, beneficial entitlement or otherwise – any significant residual interest in the infrastructure at the end of the term of the arrangement.

The Company has set forth below the principal reasons why the Ferrosur concession does not comply with the statements in section a) of
paragraph 5.

A.
The Argentine federal government (the “grantor”) does not control nor regulate the services that Ferrosur may render with the infrastructure.

i.
Ferrosur has the power to enter into freight agreements with users who undertake to use the railway and without prior consent of the grantor;

ii.
Ferrosur has provided additional services which were not available at the time the concession was granted. These additional services did not require approval from the grantor and included, for example, the
transportation of new raw materials; and

iii.
Ferrosur has built certain railroad diversions to deliver services to the Company, without the prior consent of the grantor.

B.
The grantor does not control nor regulate to whom Ferrosur must provide its services.

i.
There is no control or restriction on who can be offered the services provided by Ferrosur;

ii.
There is no preference or priority given to any public entity; and

iii.
Currently, a significant portion of the freight railway services provided by Ferrosur are to the Company and the Company has been, and continues to be, one of the principal consumers of the services provided by
Ferrosur.

C.
The grantor does not control nor regulate at what prices Ferrosur must provide the services.

i.
The concession agreement does not provide power to the grantor to exercise control over the prices that Ferrosur charges for its services.

ii.
There is no cap or limit applied by the grantor on pricing and pricing is determined on existing market conditions. Ferrosur’s principal competitors are trucks that transport raw materials and other products.

 3

 Securities and Exchange Commission

October 12, 2017

iii.
Ferrosur applies and modifies tariff rates on an ongoing basis without the consent of the grantor and the grantor does not approve the rates and tariffs.

Accordingly, the Company respectfully advises the Staff that the Ferrosur concession agreement does not meet the criteria of paragraph 5(a) of
IFRIC 12 and therefore is outside the scope of IFRIC 12.

 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 still pending” and that “the 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 Company’s Argentine legal advisors,” as indicated in your response.

 Response:

 In response to the Staff’s comment, the Company respectfully advises the Staff that it has expanded the disclosure on page F-116 of Amendment No. 2 to include in Note 36 to its audited consolidated financial statements that the Company has estimated 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 still pending and that the 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 Company’s Argentine legal advisors.

 * * *

The Company would be grateful if the Staff provided any comments to the revised Registration Statement at its earliest convenience so that the
Company may provide any additional responses required.

 Please do not hesitate to contact John Vetterli at (212) 819-8816 or John Guzman at +55 (11) 3147-5607 of White & Case LLP with any questions or comments regarding this letter.

Sincerely,

 /s/ White & Case LLP

cc:
Marcos Gradin, Chief Financial Officer, Loma Negra Compañía Industrial Sociedad Anónima

 4

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.

CORRESP
1
filename1.htm

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.

 2

 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.

 3

 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.

 4

 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:

 5

 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

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.

CORRESP
1
filename1.htm

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.

 2

 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.

 3

 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.

 4

 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.

 5

 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.

 6

 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

Mail Stop 4631

August 9, 2017

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

Re: Loma Negra Compañía Industrial Argentina Sociedad Anónima
Draft Registration Statement on Form F -1
Submitted July 12, 2017
  CIK No. 1711375

Dear Mr. Gradin :

We have reviewed your draft 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 providing the requested information and either submitting
an amended draft registration statement or  publicly  filing your registration statement on
EDGAR.  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 the information you provide in response to these  comments  and your
amended draft registration statement or filed registration statement,  we may have  additional
comments.

General

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

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

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

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 2

 beha lf, present to potential investors in reliance on Section 5(d) of the Securities Act,
whether or not they retain copies of the communication.

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 accoun ts as an operating expense
in the determination of profit before tax.

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.

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.

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.

Preemptive right s, 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.

Risk Factors, page 24

Risks Relating to the Offering, Our Ordinary Shares a nd 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

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 3

 depositary to notify ADS holders of shareholders’ meetings or where the depositary may
itself determine not to notify ADS holders.

Use of Proceeds, page 55

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

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.

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 i ncludes 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 Mea sures  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.

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 fin ancial 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.

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

General

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

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 4

 Critical Accounting Policies, page 72

Intangible Assets, page 74

15. Your disclosure states that amo rtization 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.

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.

Income Tax Expense, page 79

17. Please revise your disclosure to also quantify and discuss the reasons for any significant
diffe rences between your effective tax rate and statutory rate for each period presented.

Year Ended December 31, 2015, Compared to the Year Ended December 31, 2014, page 80

Cost of Sales, page 81

18. We refer to the cost of sales of your segments.   In your first two bullets you mention
“depreciation of the Peso against the U.S. dollar in 2015 compared to 2014”, but it is
unclear as to what costs increased due to foreign exchange.  Please revise your disclosure
to clarify the nature of the costs you  are referring to.

19. Please clarify how the costs of sales of your railroad segment are impacted by raw
materials and services which are pegged to the U.S. dollar.

Liquidity and Capital Resources, page 83

20. It appears to us that your working capital deficie ncy as of December 31, 2016, which you
have defined as current assets less current liabilities, is Ps.2,529 million.  Please advise us
how you determined your working capital deficiency amount or otherwise revise this
disclosure throughout your draft regis tration statement.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 5

 Business, page 107

21. Please include a breakdown of total revenues by category of activity for each of the last
three financial years in your description of the principal markets in which you compete.
See Item 4.B.2. of Form 20 -F.

Our Production Facilities, page 118

22. Please modify your filing and disclose details concerning your La Preferida aggregate
operation in this section.  In addition please disclose your granitic reserves after your
limestone reserve table found on page 125.

Our Production Facilities, page 119

23. Please insert a small -scale map showing the location and access to each material
property, as required by Industry Guide 7(b)(2) and Instruction 1 to Item 4.D. of Form
20-F.  We believe the maps should comply with the guidance found in Industry Guide 7,
Instructions to paragraph (c)(1).

Limestone Reserves, page 124

24. We note your disclosure of a total reserve of 949 million tons which varies from your
proven and probable reserve totals found elsewhere in your filing.  P lease review this
disclosure and revise  as necessary.

25. High quality & purity limestones are generally defined by the calcium carbonate (CaCO 3)
content as a percentage or another appropriate measurement.  Please disclose this quality
or grade for your limes tone property reserves.

26. Please modify your filing and disclose the following information within or adjacent to
your reserve tables:
 A statement, if true, clarifying your reserve estimates incorporate losses for
dilution, mining, and processing recovery and state these losses as a percentage or
other relevant factor.
 The drilling or sample density used to designate your reserves and/or separate
proven reserves from probable reserves.
 The limestone/granite cost/price used to estimate your reserves.

Management and Corporate Governance, page 137

27. Please provide the service contract disclosure or appropriate negative statement required
by Item 6.C.2 of Form 20 -F.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 6

 28. Please disclose the total amount set aside or accrued by you to provide pension,
retiremen t or other similar benefits for your executive officers and directors during the
most recently completed fiscal year. See Item 6.B.2. of Form 20 -F.

Equity Compensation Plans, page 143

29. Please provide the missing percentage amount in your next amendment.

Certain Relations and Related Party Transactions, page 146

30. Note 19 to your financial statements refer to related party transactions that occurred
during the relevant time period and that do not appear to be disclosed in this section .  See
Item 7.B of Form  20-F.

Description of Capital Stock, page 147

31. Please revise your disclosure under this heading to include the following:
 A comparison of U.S. and the Republic of Argentina laws as per Item 10.B.9 of
Form 20 -F;
 A discussion of any liability to further capital calls by the company as per Item
10.B.3(g) of Form 20 -F;
 Whether or the extent that shareholders may submit matters to be voted upon at
shareholders’ meetings; and
 Any recourse available to investors in instances where the share registry,
reference d under “Form and Transfer of Shares, page 150,” is not appropriately
updated.

Shareholders’ Liability, page 148

32. Here or under “Our shareholders may be subject to liability” on page 45, include
discussion of the following:
 Whether there are any limitatio ns on the liability that may be incurred by a
shareholder;
 Whether former shareholders may also be held liable; and
 The extent to which other matters may result in a shareholder liability, for
example, litigation initiated by shareholders.

Foreign Financi al Asset Reporting, page 170

33. Please revise to provide the relevant U.S. dollar thresholds.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 7

 Underwriting, page 173

34. We note your disclosure that your officers, directors, and selling shareholders are subject
to a lock -up agreement.  Please file the lock-up agreement as an exhibit to the registration
statement.

Enforceability of Civil Liabilities, page 188

35. Include discussion of Paraguay, as necessary, as required by Item 101(g) of Regulation S -
K.

Financial Statements, page F -1

1. General Information

36. Throughout your document, you refer to Loma Negra Holding GmbH as your selling
shareholder who owns 99.4% of your outstanding capital stock at December 31, 2016.
Please confirm to us and disclose, if true, that InterCement Brasil S.A. is the parent
company of Loma Negra Holding GmbH.

2. Basis of Preparation of the Consolidated Financial Statements, page F -9

2.3.1. Business combination between entities under common control, page F -14

37. We note your use of U.S. GAAP to account for your common c ontrol transaction.  Please
explain to us your rationale for not presenting your results of operations for 2016
assuming the exchange had occurred at the beginning of the period.  Refer to ASC 805 -
50-45 for guidance on transactions between entities under c ommon control.

4. Critical Accounting Judgments and Key Sources Used for Estimating Uncertainty, page F -28

4.1.1. Concession of Ferrosur Roca S.A.

38. Please provide us with a comprehensive analysis of your conclusion that the concession
of Ferrosur Rosa S .A. is not within the scope of IFRIC 12.  Your response should include
the specific factors you considered in your determination that the concession agreement
does not meet the criteria of paragraph 5(a) and address the applicable guidance provided
in AG2 -AG7.  Additionally, please tell us the carrying amounts of the related property,
plant, and equipment as of December 31, 2016.

15. Investments, page F -37

39. Please tell us the reason that loans receivable from InterCement Brasil  S.A. are not
classified as other receivables.  Refer to paragraph 78(b) of IAS 1.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 8

 19. Parent Company, Other Shareholders, Associates, and Other Related Parties Balances and
Transactions, page F -41

40. Please revise your draft registration statement to provide the disclosures required by
paragraph 17 of IAS 24.

21. Trade Accounts Receivable, page F -44

41. It appears that your receivable related to the railway program execution unit for Ps.78
million is not included in the line item for receivables that are  more than 91 days past
due.  Please advise, as well as tell us where this receivable is categorized in the aging of
your accounts receivable.  We further note the amount has been discounted based on the
estimated timing of collection.   Please clarify in your document the terms of the
receivable and your estimated collection schedule.

36. Receivable from Railway Program Execution Unit, page F -60

42. Please tell us whether this receivable has been collected subsequent to year -end or how
you have determined th at collectability is reasonably assured.

37. Trust Administration, page F -60

43. Please explain to us the following:
 How you accounted for the annual fee contributions prior to 2015;
 How you determined that you would receive a future economic benefit of
contributions made to a fund for the improvement of the interurban railroad
system;  and
 How you determined that gain recognition was appropriate for the prior year
contributions of Ps.84 million that were recorded by the trust and the accounting
guidance you relie d upon in your determination.

Marcos Gradin
Loma Negra Compañía Industrial Argentina Sociedad Anónima
August 9 , 2017
Page 9

You may contact 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 matte