February 11, 2025

Susan Kreh
Chief Financial Officer
Oil-Dri Corporation of America
410 North Michigan Avenue , Suite 400
Chicago , Illinois 60611

       Re: Oil-Dri Corporation of America
           Form 10-K for the Fiscal year Ended July 31, 2024
           File No. 001-12622
Dear Susan Kreh:

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

       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 10-K for the Fiscal year Ended July 31, 2024
Item 2 Properties, page 28

1.     Please revise your mineral reserve table to include the price, the
selected point of
       reference, for example in-situ, mill feed, saleable product, etc., and
the
       grade/qualities as required by Item 1303(b)(3) of Regulation S-K.
2.     We note your disclosure on page 30 stating that you do not consider any
of your
       mines to be individually material. Please quantify the number of mines
at each
       geographic location and tell us if you have considered Item 1301(c)(3)
of Regulation
       S-K in your individual property materiality analysis.
Management's Discussion and Analysis of Financial Condition and Operations
Results of Operations, page 34

3.     When more than one factor is responsible for the change in a statement
of
       operations line item between periods, please clearly quantify each of
the contributing
       factors, including any offsetting amounts. For example, you disclose
that
       your domestic cost of goods sold per ton increased 6%, driven primarily
by increases
 February 11, 2025
Page 2

       in non-fuel manufacturing and freight and offset by lower natural gas
and packaging
       costs. When you discuss net sales fluctuations, specifically describe
the extent to
       which changes are attributable to changes in prices or to changes in the
volume or
       amount of goods or services being sold or to the introduction of new
products or
       services. Refer to Item 303(b)(2) of Regulation S-K and SEC Release No.
33-8350.
Critical Accounting Policies and Estimates, page 38

4.     Please enhance your disclosure in future filings to provide qualitative
and quantitative
       information necessary to understand the estimation uncertainty and the
impact your
       critical accounting estimates have had or are reasonably likely to have
on your
       financial condition and results of operations. In doing so, discuss how
much each
       estimate and/or assumption has changed over a relevant period and the
sensitivity of
       reported amounts to the underlying methods, assumptions and estimates
used. The
       disclosures should supplement, not duplicate, the description of
accounting policies or
       other disclosures in the notes to the financial statements. Refer to
       Item 303(b)(3) of Regulation S-K and SEC Release No. 33-8350.
Notes to the Consolidated Financial Statements
Note 1 - Summary of Significant Accounting Policies
Intangibles and Goodwill, page 50

5.     We note that you allocated $20.4 million of the Ultra Pet acquisition
consideration to
       a customer list intangible asset which you amortize on a straight-line
basis over 18
       years. Please confirm whether or not this asset pertains solely to a
customer list as the
       term is described in ASC 805-20-55-21. Tell us in sufficient detail how
you
       determined the useful life of the customer list and how you considered
ASC 350-30-
       35-3 in arriving at this determination. Also clarify how you determined
it was
       appropriate to amortize the customer list on a straight-line basis, as
opposed to an
       accelerated method, and how this reflects the pattern in which you
realize the
       economic benefits of the customer list. Refer to ASC 350-30-35-6 and ASC
350-30-
       55-2 through 4.
Earnings Per Share, page 54

6.     Please address the following comments related to your utilization of the
two-class
       method to report your earnings per share:

             Tell us and revise your disclosures to clarify how you apply the
two-class method
           for diluted EPS purposes. For example, explain if you utilize for
common
           stock the more dilutive of the treasury stock method, reverse
treasury stock
           method or if-converted method and the two-class method and whether
the two-
           class method is always applied to Class B stock.

             We note your disclosure that the "impact of 158,861 shares of
unvested Common
           Stock and 54,370 shares of unvested Class B Stock, restricted stock
was anti-
           dilutive therefore not included in the calculation of diluted EPS."
Tell us how you
           determined the impact of these shares was anti-dilutive. In doing
so, specify what
           "unvested Class B Stock" represents.
 February 11, 2025
Page 3

        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 Charles Eastman at 202-551-3794 or Andrew Blume at
202-551-3254
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing