June 6, 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:   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

           Response dated May 14, 2024

           File No. 001-13357

Ladies and Gentlemen:

Royal Gold, Inc. (the “Company”) confirms receipt of your letter dated May 22, 2024 (the “Second Comment Letter”) with respect to the above-referenced Form 10-K, Form 10-K/A and initial response.

The Company continues to compile its response and respectfully requests an extension until Friday, June 14, 2024 to submit its response to the Second Comment 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