SecProbe.io

June 3, 2011
 Art A. Garcia Executive Vice President and Chief Financial Officer Ryder System, Inc. 11690 N.W. 105
th Street
Miami, FL 33178
Re: Ryder System, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2010  Filed February 15, 2011  File No. 001-04364

Dear Mr. Garcia:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within 10 bus iness days by confirming that you will revise
your document in future filings, amending your filing(s) as appropria te, and providing any
requested information.  If you do not believe  our comments apply to your facts and
circumstances, please tell us why in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

UForm 10-K for Fiscal Year Ended December 31, 2010

UItem 1A. Risk Factors, page 12
 1. We note the statement on page 12 that “[i]n additi on to the factors discussed elsewhere in this
report, the following are some of the important factors that could aff ect our business.”  All
material risks should be discussed in this se ction.  Please confirm that you will revise this
language in future filings to state that you ha ve disclosed all known material risks in this
section.

Art A. Garcia
Ryder System, Inc. June 3, 2011 Page 2

Management’s Discussion and Analysis

Full Year Consolidated Results, page 25 and Full  Year Operating Results by Business Segment,
page 31
 2. Please quantify each factor cited as a cause fo r a variance so that investors may have a
context of their magnitude and relative impact .  Refer to section 501.04 of the Codification of
Financial Reporting Releases fo r guidance in regard to quan tification of cited factors.
 Full Year Consolidated Results, page 25

 3. We note that “operating expenses ” is material to your results  and represents your largest
expense category that is approximately 50% of your total costs and expenses.  It also  appears
to consist of several items.  Please identify and quantify, preferably in comparative tabular
fashion, the principal components of this line  item so that investors may readily understand
the magnitude and relative impact of each in contributing to your results.  Accompany the presentation with an appropria te level of comparative analys is.  Refer to 303(A)(3)(i) of
Regulation S-K and instruction 4 to Item 303( A).  Please provide us with your intended
revised presentation.
 Full Year Operating Results by Business Segment, page 31

4. To the extent that changes in costs and expe nses materially impact each segment’s measure
of profit, please discuss and quantify the imp act of each material component.   We also
encourage that you alternatively consider disc losure, preferably in  comparative tabular
fashion, of the principal costs and expenses a ssociated with each segment in arriving at
“segment NBT.”  This will more easily perm it investors to readily identify and understand
the cost and expense components associated with  each segment as well as the magnitude and
relative impact of each in contributing to each segment’s results.  In addition, please
accompany the presentation with an appropria te level of compar ative analysis.
 Critical Accounting Estimates

Revenue Recognition, page 54
 5. In the “Revenue Recognition” po rtion of note 1 of the notes to the consolidated financial
statements, you state that you make judgments about  whether pricing is fixed or determinable
and whether or not collectability is reasonably assured.  Please discuss the judgments that are
made for these purposes and the impact of such in determining the amount of revenue
recorded.
 Consolidated Statements of Earnings, page 63

 6. We note that you solely report “Revenue” as one aggregate amount a nd caption in your
Consolidated Statements of Earnings.  Ho wever, in your Business (Item 1) section
disclosures on your three reporta ble business segments, we note that you have substantive
and separate revenue producing ac tivities from rentals (including leasing) and from services.

Art A. Garcia
Ryder System, Inc. June 3, 2011 Page 3

Specifically, you have commercial rental and full-serv ice leasing of various types of vehicles.
In addition, you have contract-rel ated maintenance and fleet s upport services (separate from
your leasing contracts) as well as service cont racts through your various logistic management
and dedicated contract carriages service activi ties.  As such, it does not appear that your
business operations and activities enable you to report all revenues solely in one caption and
amount.

In accordance with the guidance in Rule 5-03( b)(1) of Regulation S-X, registrants should
separately report on the face of the consolidated statemen ts of earnings amounts of revenues
from services as well as revenues from rentals,  if each of these reve nue producing activities
exceeds 10% of total revenues.  In connection w ith the separate reporting of these revenue
producing activities, the amount of direct costs and expenses attributable to each of these two
significant revenue producing activ ities should also be reported se parately on the face of the
consolidated statements of earnings, in accordan ce with the guidance in Rule 5-03(b)(2) of
Regulation S-X.  In this regar d, we believe that rental activities include both commercial
rental and leasing of vehicles.  In this re gard, ASC Topic 840 (Leases) further supports this
treatment as payments received under operating leases re present rental income.  Therefore, as
it appears that your reporting of  revenues should be disaggregated  into these two material and
separate revenue producing activities, please revise your Consolidated Statements of
Earnings to be consistent w ith the general repor ting format and presentation under Rules 5-
03(b)(1)-(2) of Regulation S-X, accordingly.

7. Reference is made to note (1) on page 26 with respect to your non-GAAP operating
performance measure for “operating revenues” wh ich excludes fuel services and subcontract
transportation revenues.  You state that these revenue components are excluded from the
operating performance measure of  operating revenues as they are largely a pass-through to
your customers and you realize minimal changes in  profitability from these items in certain
instances.  As these items are different than  your other revenue produc ing activities and not
used in evaluating performance of the busines ses and as a measure of sales activity, we
suggest that you consider separa te reporting of these revenue components on the face of your
Consolidated Statements of Earnings.   In addition, please note that separate repor ting of fuel (surcharge) revenues provides a
consistent and similar statement of operati ons presentation used by other transportation
industry registrants.  Furthermore, as you report subcontract transportation expense
separately on your Consolidated Statement of  Earnings, the reporting of its associated
revenues separately on the face of the statemen t will provide a consistent presentation for
both the related revenues and expenses.  Also, the separate reporting of these two revenue
components on the face of the statement will segregate these items directly from your
operating revenues and may eliminate the need to report a non-GAAP operating performance
measure (as these items will already be excl uded from your other operating revenues).
Please re-evaluate and advise accordingly.

Art A. Garcia
Ryder System, Inc. June 3, 2011 Page 4

Notes to Consolidated Financial Statements

Note 1. Summary of Significant Accounting Policies
Accounts Receivable Allowance, page 69
 8. For purposes of here as well as the portion of “revenue recognition” within note 1 in regard
to direct financing leases of  the “Fleet Management Solutions” segment, please disclose
when you consider receivable s to be uncollectible.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Doug Jones at 202-551-3309 or Joe Foti at 202-551-3816 if you have
questions regarding comments on th e financial statements and rela ted matters.  Please contact
Lauren Nguyen at 202-551-3642 or Justin Dobbi e at 202-551-3469 concerning other matters.
You may also contact me at  202-551-3380 with any questions.

Sincerely,
      Lyn Shenk
Branch Chief