April 29, 2019

William Heissenbuttel
Chief Financial Officer
Royal Gold, Inc.
1660 Wynkoop Street, Suite 1000
Denver, CO 80202

       Re: Royal Gold, Inc.
           Form 10-K for Fiscal Year Ended June 30, 2018
           Filed August 9, 2018
           File No. 001-13357

Dear Mr. Heissenbuttel:

       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.

Form 10-K for Fiscal Year Ended June 30, 2018

Item 1. Business
Our Operational Information, page 4

1.    Since the net revenue amounts presented deduct cost of sales, they do not
appear to reflect
      your ASC 605/606 revenue. Please retitle the net revenue measures here
and throughout
      the filing to better convey what they actually represent. Also, if the
net revenue combined
      amounts are non-GAAP measures and presented outside of the segment
footnote
      reconciliation, either remove the combined amounts or provide the
disclosures required by
      Item 10(e) of Regulation S-K. If you believe the net revenue combined
amounts are not
      non-GAAP measures, tell us why, including explaining how you determined
that you are
      not presenting a figure for income before depreciation, depletion and
amortization. Refer
      to Question 104.04 of the Division's Non-GAAP Financial Measures
Compliance and
      Disclosure Interpretations and SAB Topic 11:B.
 William Heissenbuttel
Royal Gold, Inc.
April 29, 2019
Page 2


Item 8. Financial Statements and Supplementary Data
Consolidated Statements of Operations and Comprehensive (Loss) Income, page 50

2.       Please relabel the cost of sales line item here and elsewhere
throughout the filing to state
         that it excludes depreciation, depletion and amortization. Refer to
SAB Topic 11:B.
        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 James Giugliano at (202) 551-3319 or Rufus Decker at
(202) 551-
3769 if you have any questions.



                                                                Sincerely,
FirstName LastNameWilliam Heissenbuttel
                                                                Division of
Corporation Finance
Comapany NameRoyal Gold, Inc.
                                                                Office of
Beverages, Apparel and
April 29, 2019 Page 2                                           Mining
FirstName LastName