SecProbe.io

May 14, 2012
 Via E-mail

Art A. Garcia 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, 2011
Filed February 16, 2012 Form 10-Q for Quarterly Period Ended March 31, 2012 Filed April 24, 2012 File No. 001-04364

Dear Mr. Garcia:
 We have reviewed your filings and have th e following comments.  In our comments, we
may ask you to provide us with informati on 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 and providing an y requested information.  If you do not believe
our comments apply to your facts and circumst ances, please tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.
            Form 10-Q for Fiscal Quarter Ended March 31, 2012

 Notes to the Condensed Conso lidated Financial Statements

Note (K) Accrued Expenses and Other Liabilities, page 11

1. We note that salary and wages decrease d $59.0 million to $62.0 million at March 31,
2012 from $121.1 million at December 31, 2011.  Pl ease explain to us the reason for the
decrease.
 Note (T) Other Matters, page 21

2. You disclose that the final re solution of matters  indicated in this note could have a
material effect on your consolidated operating results.  If there is at least a reasonable
possibility that a loss exceeding amounts alrea dy recognized may have been incurred, in
your next periodic filing please di sclose either an estimate (o r, if true, state that the

Art A. Garcia Ryder System, Inc. May 14, 2012 Page 2

 estimate is immaterial in lieu of providing quantified amounts)  of the additional loss or
range of loss, or state that such an estima te cannot be made.  Please refer to ASC 450-20-
50 -4.b.

If you conclude that you cannot estimate the reasonably possible addi tional loss or range
of loss, please (1) explain to us the pro cedures you undertake on a quarterly basis to
attempt to develop a range of reasonably possible loss for disclosure and (2) for each
material matter, what specif ic factors are causing the inab ility to estimate and when you
expect those factors to be al leviated.  We recognize there are a number of uncertainties
and potential outcomes associated with loss cont ingencies.  Nonetheless, an effort should
be made to develop estimates for purposes of disclosure, including determining which of
the potential outcomes are reasonably possible and what the reasonabl y possible range of
losses would be for those reasonab ly possible outcomes.
 You may provide your disclosures on an aggr egated basis.  Please include your proposed
disclosure in your response.
 Management’s Discussion and Analysis

Financial Resources and Liquidity
Cash Flows, page 33

3. You disclose that cash provided by operati ng activities from continuing operations
decreased in the three months ended March 31, 2012 compared with 2011 because of an
increase in working capital needs, and that the increase in working capital was driven by
planned cash payments specific to the first quarter.  Please explain to us and disclose
what working capital needs increased and why, and what the planned cash payments
specific to the first quarter were and the re ason for them.  Quantify associated amounts as
appropriate so that investors may understand the relative magnit ude of each item.  Please
note that reference to changes in balance shee t items in regard to working capital changes
may not be sufficient in explaining change s in operating cash flows without further
discussion of how such dire ctly affected cash.

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;

Art A. Garcia Ryder System, Inc. May 14, 2012 Page 3

  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 Theresa Me ssinese at 202-551-3307 or Doug Jones at 202- 551-3309 if
you have questions regarding the comments and re lated matters.  Please contact me at 202-551-
3380 with any other questions.
Sincerely,
   /s/ Lyn Shenk    Lyn Shenk
Branch Chief