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                             April 9, 2024

       William Heissenbuttel
       President and Chief Executive Officer
       Royal Gold, Inc.
       1144 15th Street, Suite 2500
       Denver, CO 80202

                                                        Re: Royal Gold, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2023
                                                            Form 10-K/A for the
Fiscal Year Ended December 31, 2023
                                                            File No. 001-13357

       Dear William Heissenbuttel:

                                                        We have reviewed your
filing 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/A for the Fiscal Year Ended December 31, 2023

       Item 2. Properties, page 4

   1.                                                   We note your disclosure
on page 4 stating that SK 1300 does not permit the substitution of
                                                        resources or reserves
prepared under another regime. However the mineral resource and
                                                        mineral reserve summary
tables beginning on page 9, and the mineral resource and
                                                        mineral reserve tables
included with your individual property disclosure, with the
                                                        exception of certain
properties, have been prepared under other mineral reporting regimes,
                                                        and are not compliant
with SK 1300.

                                                        Absent SK 1300
compliant mineral resources and mineral reserves, the
                                                        accommodations under
Item 1303(a)(3) and 1304(a)(2) of Regulation S-K for royalty and
                                                        streaming companies
permit the omission of information, including mineral resources and
                                                        mineral reserves. These
accommodations do not permit the substitution of mineral
                                                        resources and mineral
reserves prepared under other mineral reporting regimes. Please
                                                        revise to remove
resources and reserves from your filing that are not SK 1300 compliant.

                                                        Please ensure all
mineral resources and mineral reserves in your filing are presented
 William Heissenbuttel
Royal Gold, Inc.
April 9, 2024
Page 2
         corresponding to your fiscal year end, and include the point of
reference, consistent with
         the requirements of Item 1303(b)(3) and Item 1304(d)(1) of Regulation
S-K.
2.       We note your disclosure on page 4 with respect to internal controls as
they relate to
         mineral resource and mineral reserve reporting. In a separate section
of your filing please
         provide the disclosure required by Item 1305 of Regulation S-K. We
understand that you
         do not prepare estimates of mineral resources and reserves, however
your disclosure on
         page 4 states that, in your view, these estimates are material to
investors. Further we note
         these numbers, although provided by other operators, are used in
accounting estimates
         such as impairment and depreciation analyses, as noted on page 76 of
your Form 10-K
         filed February 15, 2024. As a royalty and streaming company this
disclosure may include
         verification procedures or other analytical means that your company
uses to track and
         report mineral resources and mineral reserves.

         Nonetheless, if these or similar processes are not in place include a
statement to this affect
         in this section of your filing.
3.       We note your disclosure of aggregate annual production for all
properties. Item
         1303(b)(2)(iv) of Regulation S-K requires a registrant with a royalty
or similar economic
         interest to provide only the portion of production that led to royalty
or other incomes for
         each of the three most recently completed years. Please tell us if the
production numbers
         presented in the table reflect the portion of production that led to
royalty or other income
         and, if not, revise to comply with the instruction.
        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 Paul Cline at 202-551-3851 or Jennifer Monick at
202-551-3295 if you
have questions regarding comments on the financial statements and related
matters. If you have
questions regarding comments on mining operations, please contact John Coleman
at 202-551-
3610 or Craig Arakawa at 202-551-3650.



FirstName LastNameWilliam Heissenbuttel                         Sincerely,
Comapany NameRoyal Gold, Inc.
                                                                Division of
Corporation Finance
April 9, 2024 Page 2                                            Office of Real
Estate & Construction
FirstName LastName