SecProbe.io

April 11, 2013

Via E -mail
Art A. Garcia
Executive Vice President and Chief Financial Officer
Ryder System, Inc .
11690 N.W. 105th Street
Miami, Florida 33178

Re: Ryder System , Inc.
  Form 10 -K for Fiscal Year Ended December 31, 2012
             Filed on February 14, 2013
             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 r espond to this letter within 10  business days by confirming that you will revise
your document in future filings  and providing  any reque sted information.   If you do not believe
our c omments 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.

Form 10 -K for Fis cal Year Ended December 31, 2012

Item 8. F inancial Statements and Supplementary Data

Notes to Consolidated Financial Statements

Note 14. Income Taxes , Like Kind Exchange Program, page 77

1. We note effective April 1, 2012, that you temporarily suspended the like -kind exchange
program. Please tell us and disclose the  reason for suspending this program and the
impact of this suspension  on your tax provision and cash flows (for example, taxes
currently payable and restricted cash) for fiscal 2012 and future periods expected to be
affected.  Also, tell  us and disclose whether you intend to reinstitute this program and
when, and the factors upon which you will base your decision.  Additionally, tell us and
disclose if suspension of this program impacted or is expected to impact your capital

Art A. Garcia
Ryder System , Inc.
April  11, 2013
Page 2

 program, and the degree of the impact, including retention, aging and depreciation of the
affected assets.

Note 23. Share -Based Compensation Plans, page 88

2. We note from exhibits included with forms filed with the commission during 2012 that
performance based rest ricted stock rights, restricted stock rights and stock options or
stock appreciation rights awards granted in 2012 appear to have dividend equivalent
rights.  In regard to performance based restricted stock rights and restricted stock rights,
cash is paid equal to the aggregate dividends paid on a share during the period from the
date of grant of the award until the date the shares underlying the award are delivered.  In
regard to stock options or stock appreciation rights, dividend equivalents may accrue o n
such unvested awards and be paid to the extent the shares vest.  Please disclose these
features of the 2012 awards.  With respect to these features, please explain to us your
accounting and reporting and the basis for such, including your consideration o f ASC
710-10 and 260 -10.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rul es require.   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 provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

You may contact Aamira Chaudhry a t 202 -551-3389  or Doug Jones at 202 -551-3309  if
you have questions regarding comments on the financial statements and related matters . You
may also contact me at 202 -551-3380.

Sincerely,

 /s/ Lyn Shenk

 Lyn Shenk
Branch Chief