September 21, 2006 Mr. Jim B. Rosenberg Senior Assistant Chief Accountant United States Securities and Exchange Commission 450 Fifth Street, N.W. Mail Stop 6010 Washington, D.C. 20549 RE: Old Republic International Corporation Form 10-K for fiscal year ended December 31, 2005 File No. 001-10607 Dear Mr. Rosenberg: We have received your letter of September 8, 2006 and acknowledge your request that we respond within ten business days to the inquiries cited in the letter. In consideration of other significant time commitments, we are unable to fully respond within the prescribed time period. Accordingly, we ask that you allow us up to an additional ten business days to submit our written response. Sincerely, OLD REPUBLIC INTERNATIONAL CORPORATION /s/ Karl W. Mueller Karl W. Mueller Senior Vice President/Chief Financial Officer cc: A. C. Zucaro Chairman/Chief Executive Officer