May 8, 2024

VIA EDGAR

Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate & Construction

100 F Street, N.E.

Washington, D.C. 20549

Attn:   Paul Cline

           Jennifer Monick

           John Coleman

           Craig Arakawa

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

Ladies and Gentlemen:

Royal Gold, Inc. (the “Company”) previously requested an extension to May 7, 2024 to respond to the comments in your letter dated April 9, 2024 with respect to the above-referenced Form 10-K and Form 10-K/A.

The Company continues to compile its response and respectfully requests a further extension until Monday, May 13, 2024 to submit its response letter.

In the meantime, if you have any questions, please do not hesitate to contact the undersigned by telephone at (303) 573-1660, or Paul Hilton of Hogan Lovells US LLP by telephone at (303) 454-2414 or by email at paul.hilton@hoganlovells.com.

Sincerely,

/s/ William Heissenbuttel

William Heissenbuttel

President & Chief Executive Officer

cc:    Paul Hilton, Hogan Lovells US LLP