May 16, 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
           Response dated May 6, 2019
           File No. 001-13357

Dear Mr. Heissenbuttel:

       We have reviewed your May 6, 2019 response to our comment letter and
have the
following comment. 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 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
April 29, 2019 letter.

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

Item 1. Business
Our Operational Information, page 4

1.    In your response to comment 1, you state that the net revenue measure
reflects the revenue
      recognized under your stream and royalty agreements and the cost paid for
metal
      delivered pursuant to your stream agreements and is more akin to gross
profit. Please
      modify the title of this measure throughout your filings and releases to
more properly
      reflect its nature and to avoid the implication that this is a measure of
revenue, which
      would be gross of cost of sales. Please also ensure the title used makes
clear that the
      measure excludes depreciation, depletion and amortization. Refer to SAB
Topic 11:B.
 William Heissenbuttel
Royal Gold, Inc.
May 16, 2019
Page 2

       You may contact James Giugliano at (202) 551-3319, or Rufus Decker at
(202) 551-
3769, with any questions.



                                                        Sincerely,
FirstName LastNameWilliam Heissenbuttel
                                                        Division of Corporation
Finance
Comapany NameRoyal Gold, Inc.
                                                        Office of Beverages,
Apparel and
May 16, 2019 Page 2                                     Mining
FirstName LastName