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Investors Title Company
121 North Columbia Street
Chapel Hill, NC 27514



                                  June 6, 2005



Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC  20549

Re:  Investors Title Company
     Form 10-K for the fiscal year ended December 31, 2004
     File No. 000-11774

Dear Mr. Rosenberg:

We have reviewed the comment included in your letter dated May 24, 2005
regarding the Form 10-K filed by Investors Title Company (the Company) for the
fiscal year ended December 31, 2004. The Company is requesting confidentiality
pursuant to the Commission's Rule 83 for one sentence of this response letter
which is redacted from this EDGAR filing. The unredacted letter and accompanying
request are being sent under separate cover. Following is the Commission's
comment and the Company's response:

Comment 1: Critical Accounting Policies - Reserves for Claims
-------------------------------------------------------------

Comment:  We believe your disclosure in Management's Discussion and Analysis
          regarding the reserve for claims could be improved to better explain
          the judgments and uncertainties surrounding this estimate and the
          potential impact on your financial statements. We believe that
          disclosures explaining the likelihood that materially different
          amounts would be reported under different conditions or using
          different assumptions is consistent with the objective of Management's
          Discussion and Analysis. Accordingly, please provide us information
          supporting this objective including the following information as well
          as your analysis supporting why you excluded this information from the
          filing:

          Please provide the range of loss reserve estimates as determined by
          your actuaries. Discuss the key assumptions used to arrive at
          management's best estimate of loss reserves within that range and what
          specific factors led management to believe this amount rather than any
          other amount within the range represented the best estimate of
          incurred losses. In addition include quantified and narrative
          disclosure of the impact that reasonably likely changes in one or more
          of the variables (i.e. actuarial method and/or assumptions used) would
          have on reported results, financial position and liquidity.

<PAGE>


          If you do not calculate a range around your loss reserve, but instead
          use point estimates please tell us:

               o    The various methods considered and the method that was
                    selected to calculate the reserves. If multiple point
                    estimates are generated, include the range of these point
                    estimates. Include a discussion of why the method selected
                    was more appropriate over the other methods.

               o    How management determined the most appropriate point
                    estimate and why the other point estimates were not chosen.
                    Also clarify whether the company actually records to the
                    point estimate or if not, how that estimate is used.

               o    The quantified and narrative impact that reasonably likely
                    changes in one or more of the variables (i.e. actuarial
                    method and/or assumptions used) would have on reported
                    results, financial position and liquidity.

          Based on your disclosure it is unclear whether you accrue your policy
          reserve when the premiums are recognized as revenue. Please tell us
          management's policy for recognizing claim reserves and how your policy
          complies with paragraph 17 of SFAS 60.


Response: The Company records the claims provision as a percentage of premium
          income. The Company considers factors such as the Company's historical
          loss experience, case reserve estimates on reported claims, large
          claims and other relevant factors in determining the aggregate
          recorded expected liability for claims. Events such as fraud,
          defalcation and multiple property defects can cause increases in
          estimates of claim liabilities. Title claims can be complex and may
          involve uncertainties as to ultimate exposure. In addition, some
          claims may require a number of years to settle, and therefore
          determine the final liability for indemnity and loss adjustment
          expense.

          The Company utilizes an independent actuarial consultant to comply
          with the reporting requirements of the National Association of
          Insurance Commissioners. The actuary has significant expertise in the
          title industry and strives to stay abreast of recent trends that could
          affect exposure to losses. Management reviews the actuarial loss and
          loss adjustment expense reserve estimates prepared by the independent
          consulting actuary along with factors discussed in the preceding
          paragraph in determining its aggregate recorded expected liability for
          claims.

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          For title insurance, case reserves on reported claims alone are an
          insufficient measure of the ultimate cost due in part to the longer
          claim-tail, the greater likelihood of protracted litigation and the
          limited facts available at the time the claim is first reported. The
          aggregate recorded liability consists of case reserves on reported
          claims and an estimate for claims that have been incurred but not
          reported (IBNR).

          The Company's independent consulting actuary provides both a range of
          reasonable estimates for claims reserves and a selected estimate to
          management. In establishing management's best estimate, the Company
          compares the actuary's projections to the reserves recorded by
          management to evaluate the adequacy of claims reserves. The Company's
          claims reserves at December 31, 2004 were $31,842,000, including
          reserves for known and IBNR claims. At December 31, 2004, the Company
          recorded its reserves at the actuary's selected estimate adjusted
          upward for facts discovered in January 2005 regarding two large claims
          that could potentially increase the Company's exposure. To date, these
          claims are still pending, so ultimate exposure is still uncertain at
          this time. The Company's recorded reserves at December 31, 2004 were
          still within the recommended range provided by the independent
          consulting actuary.

          In a separate confidential letter to the Commission, the independent
          consulting actuary's reserve range and selected estimate are provided.
          Note the independent consulting actuary considers this information
          privileged and confidential. Therefore, this information has been
          excluded from this letter and SEC filings.

          The Company's actuarial consultant applied the following four loss
          development methods to case incurred and paid losses with allocated
          loss adjustment experience (ALAE): paid loss development method,
          incurred loss development method, a Bornhuetter-Ferguson Method on a
          paid loss development basis and a Bornhuetter-Ferguson Method on an
          incurred loss development basis. He analyzed "jumbo" and "non-jumbo"
          claims experience separately. "Jumbo" claims were considered to be
          those claims exceeding $100,000 individually. This definition of
          "jumbo" and "non-jumbo" was established by management and he found
          this definition to be reasonable.

          The loss development methods separately projected ultimate loss and
          ALAE for each policy year on the basis of historical emergence
          patterns in the Company's incurred and paid loss data. The actuary
          used the Company's loss data to estimate reporting and payment
          patterns. He applied actuarial judgment in selecting the loss
          development factors underlying this analysis so that the most recent
          three policy years of experience were properly reflected in his
          selected estimate.

<PAGE>


          The Bornhuetter-Ferguson Methods utilize premiums written plus other
          income as the exposure base. The initial loss and ALAE ratios used in
          the Bornhuetter-Ferguson Methods were based on the Company's
          historical loss and ALAE ratios by policy year.

          Prior to establishing his estimate for year-end 2004 loss and loss
          adjustment expense reserves, the consulting actuary reviewed the
          Company's most recent loss experience and, based upon his
          interpretation of the results associated with policy years 2002, 2003
          and 2004, he concluded that additional weight should be applied to the
          more recent experience. It was the actuary's belief that the most
          recent three years of policy year experience would be more relevant
          than older policy years. Older policy years were relied upon; however,
          the analysis of jumbo losses and non-jumbo losses over the most recent
          three policy years was a critical consideration in the actuary's
          selection of his estimate.XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
          XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
          XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
          XXXXXXXXXXXXXXXXXX.  Management increased the actuary's selected
          estimate to $31,842,000 due to facts discovered regarding the two
          large claims noted earlier.

          Changes in variables or assumptions primarily affect the loss ratio.
          The actual loss ratio in 2004 was 11.1%. If one or more of the
          variables (i.e. actuarial method and/or assumptions used) changed such
          that the Company's loss ratio increased or decreased approximately 10%
          or one percentage point, the impact on after-tax income for the year
          ended December 31, 2004 follows:

          Increase of Loss Ratio of 1%                                $(474,000)
          Decrease in Loss Ratio of 1%                                  474,000

          Based upon management's discussions with its independent consulting
          actuary, management does not believe that it is reasonably likely that
          changes in one or more of the variables would have a material impact
          on reported results, financial position or liquidity. Although the
          actuarial assumptions utilized by the independent consulting actuary
          are consistent with the historical operating results of the Company,
          each of the methodologies utilized by the independent consulting
          actuary would respond to changes in variables or assumptions.
          Specifically, the paid loss development method would respond to
          changes in the payment patterns associated with claim and loss
          adjustment expenses. The incurred loss development method, which
          includes claims reserves as well as claim payments, would respond to
          underlying changes in case reserving or claim reporting patterns. The
          Bornhuetter-Ferguson Methods, on either a paid basis or an incurred
          basis, would respond to changes in variables while simultaneously
          being responsive to changes in premium levels and a changing loss
          ratio assumption consistent with the independent actuary's selection
          of a target loss ratio for the Bornhuetter-Ferguson Methods. By
          reviewing the unadjusted loss and loss adjustment expense reserve
          estimates of a variety of generally accepted actuarial methodologies,
          in conjunction with consideration of the more recent loss experience
          of the Company, the consulting actuary provides management with his
          recommended range of reasonable results, his selected loss reserve and
          an explanation of the methodologies that he has utilized.

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          In the Title Insurance segment, the Company records its provision for
          future claims payments at the time premiums are recognized as revenue
          in accordance with paragraph 17 of SFAS 60. In future filings with the
          Commission, the Company will provide additional disclosures consistent
          with the resolution of this inquiry.

          As required by the Commission, the Company acknowledges that:

          o    The Company is responsible for the adequacy and accuracy of the
               disclosure in the filing;

          o    Staff comments or changes to disclosure in response to staff
               comments in the filings reviewed by the staff do not foreclose
               the Commission from taking any action with respect to the filing;
               and

          o    The Company may not assert staff comments as a defense in any
               proceeding initiated by the Commission or any person under the
               federal securities laws of the United States.

If you have further questions, please contact me at 919-968-2200.


                                                     Sincerely,

                                                     /s/ James A. Fine, Jr.
                                                     ----------------------
                                                     James A. Fine, Jr.
                                                     President and CFO
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