October 15, 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

           Paul Cline

           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 October 11, 2024 to respond to the comment in your letter dated September 13, 2024 with respect to the above-referenced Form 10-K and Form 10-K/A.

The Company continues to consider, with the assistance of its advisors, its response to the September 13, 2024 letter and respectfully requests an extension until Friday, October 18, 2024 to submit its response.

In the meantime, if you have any questions, please do not hesitate to contact the undersigned by telephone at (303) 573-1660.

Sincerely,

/s/ William Heissenbuttel

William Heissenbuttel

President & Chief Executive Officer