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corresp

July 8, 2011

Doug Jones

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-3561

               Re:

    Ryder System, Inc.

Form 10-K for the Year Ended December 31, 2010

Filed February 15, 2011

File Number: 001-04364

Dear Mr. Jones:

On behalf of Ryder System, Inc. (“Ryder”) we hereby respond to the comments provided by the Staff
of the Securities and Exchange Commission (the “Commission”) in its letter dated June 3, 2011.
For ease of reference, we have included the Staff’s comments in their entirety in italicized text
preceding each of our responses.

Form 10-K for the Year Ended December 31, 2010

Item 1A. Risk Factors, page 12

    1.

    We note the statement on page 12 that “[i]n addition to the factors discussed elsewhere in
this report, the following are some of the important factors that could affect our business.”
All material risks should be discussed in this section. Please confirm that you will revise
this language in future filings to state that you have disclosed all known material risks in
this section.

     We acknowledge the Staff’s comments and confirm that in future filings we will state that all
known material risks are included under “Risk Factors.”

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 for 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 for guidance in regard to quantification of cited factors.

Securities and Exchange Commission

July 8, 2011

Page 2 of 9

     We acknowledge the Staff’s comment and the requirements of section 501.04 of the Codification
of Financial Reporting Releases to quantify the factors that materially impact our consolidated and
segment results.

     In drafting our Management’s Discussion and Analysis (MD&A), we currently provide the drivers
of the change in the order of their magnitude. In future filings, beginning with our Quarterly
Report on Form 10-Q for the period ended June 30, 2011 (the “Second Quarter Form 10-Q”), we will
provide the magnitude and relative impact of the material factors consistent with the requirements
of section 501.04 of the Codification of Financial Reporting Releases.

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 appropriate level of comparative analysis. 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.

     We acknowledge the Staff’s comment and are proposing to change the face of our Consolidated
Statement of Earnings to identify the following principal components of “operating expenses.”

    Years ended December 31,

    2010

    2009

    Fuel

    $
    840,257

    717,314

    Maintenance and repairs

    856,557

    793,169

    Other Operating Expenses

    745,110

    719,056
    (1)

    $
    2,441,924

    2,229,539

    (1)

    Other operating expenses include taxes and licensing costs, facilities, insurance,
professional services and outside labor. None of these items are individually significant
(<10% of total costs).

     Our MD&A will contain a discussion of each of these expense line items with the appropriate
level of comparative analysis. We believe this enhanced presentation of our Consolidated Statement
of Earnings and MD&A will provide information surrounding the principal components of the previous
“operating expenses” line so that investors may

Securities and Exchange Commission

July 8, 2011

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readily understand the magnitude and relative
impact of each of the principal expenses in contributing to our results.

     As discussed, we will implement these proposed changes to the Statement of Earnings and MD&A
beginning with our Quarterly Report on Form 10-Q for the period ending September 30, 2011.

Full Year Operating Results by Business Segment, page 31

    4.

    To the extent that changes in costs and expenses materially impact each segment’s measure of
profit, please discuss and quantify the impact of each material component. We also encourage
that you alternatively consider disclosure, preferably in comparative tabular fashion, of the
principal costs and expenses associated with each segment in arriving at “segment NBT.” This
will more easily permit investors to readily identify and understand the costs 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 appropriate level of comparative analysis.

     In future filings, beginning with the Second Quarter Form 10-Q, we will enhance our disclosure
regarding the changes in costs and expenses that materially impact the profitability of each
reportable business segment. Specifically, we intend to:

    a.

    Expand the Overview section of the MD&A to provide an executive summary of
the cost and expense components associated with each segment, as well as the material
factors and trends that impact such components;

    b.

    Expand the Consolidated Results section to identify the business segment
being impacted by the applicable change in expense; and

    c.

    Expand the Operating Results by Business Segment section to discuss and
quantify changes in principal costs and expenses that materially impact segment NBT.

     We believe these expanded disclosures will more easily permit 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 the segment results.

Securities and Exchange Commission

July 8, 2011

Page 4 of 9

Critical Accounting Estimates

Revenue Recognition, page 54

    5.

    In the “Revenue Recognition” portion 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.

Fixed and Determinable

     We supplementally advise the Staff that in our evaluation of whether revenue is fixed or
determinable, we determine whether the total contract consideration in the arrangement could change
based on one or more factors. These factors vary among each of our segments. Generally, the
judgments made for these purposes do not materially impact the revenue recognized in any period.

     In our Fleet Management Solutions (FMS) segment, the factors evaluated in determining whether
revenue is fixed or determinable primarily relate to (i) changes in the consumer price index (CPI)
and (ii) vehicle usage. Our lease agreements allow for rate changes based on changes in CPI.
Lease and rental agreements also provide for vehicle usage charges based on a time charge and/or a
fixed per-mile charge. The changes in rates attributed to changes in the CPI and vehicle usage
charges are contingent rentals. The contingent portion of the revenue in these arrangements is not
considered fixed or determinable until the effect of CPI changes is implemented or the equipment
usage occurs.

     In our Supply Chain Solutions (SCS) segment, the factors evaluated in determining whether
revenue is fixed or determinable primarily relate to the satisfaction of performance contingencies.
In certain SCS contracts, a portion of the contract consideration may be contingent upon the
satisfaction of performance criteria, attainment of pain / gain share thresholds or volume
thresholds. The contingent portion of the revenue in these arrangements is not considered fixed or
determinable until the performance criteria or thresholds have been met.

Collectibility

     We supplementally advise the Staff that our judgments on collectibility are initially
established when a business relationship with a customer is initiated and is continuously monitored
as services are provided. We have a credit rating system based on internally developed standards
and ratings provided by third parties. Our credit rating system, along with monitoring for
delinquent payments, allows us to make decisions around when collectibility may not be reasonably
assured. Factors considered during this process include historical payment trends, industry risks,
liquidity of the customer, years

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July 8, 2011

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in business, and judgment, liens or bankruptcies. When collectibility is not considered
reasonably assured (typically when a customer is 120 days past due), revenue is not recognized
until cash is collected from the customer.

     In future filings, beginning with our Annual Report on Form 10-K for the period ending
December 31, 2011, we will enhance our disclosures in Note 1 to the Consolidated Financial
Statements surrounding our judgments around revenue recognition and collectibility and whether the
impact of any judgments is material.

Consolidated Statements of Earnings, page 63

    6.

    We note that you solely report “Revenue” as one aggregate amount and caption in your
Consolidated Statements of Earnings. However, in your Business (Item 1) section disclosures
on your three reportable business segments, we note that you have substantive and separate
revenue producing activities from rentals (including leasing) and from services.

    Specifically, you have commercial rental and full-service leasing of various types of
vehicles. In addition, you have contract-related maintenance and fleet support services
(separate from your leasing contracts) as well as service contracts through your various
logistic management and dedicated contract service activities. 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 statement of earnings amounts of revenues
from services as well as revenues from rentals, if each of these revenue producing
activities exceeds 10% of total revenues. In connection with the separate reporting of
these revenue producing activities, the amount of direct costs and expenses attributable to
each of these two significant revenue producing activities should also be reported
separately on the face of the consolidated statements of earnings, in accordance with the
guidance in Rule 5-03(b)(2) of Regulation S-X. In this regard, we believe that rental
activities include both commercial rental and leasing of vehicles. In this regard, ASC
Topic 840 (Leases) further supports this treatment as payments received under operating
leases represent 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 with the general
reporting format and presentation under Rule 5-03(b)(1)-(2) of Regulation S-X, accordingly.

     As discussed, in considering our response to this Comment 6, we wish to refer the Staff to its
comment letter dated October 21, 2002 relating to Ryder’s Annual Report on Form 10-K for the period
ended December 31, 2001 and Ryder’s response dated October 31, 2002. In Comment 2 of the Staff’s
2002 comment letter, the Staff requested that we

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July 8, 2011

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provide separate disclosure of revenues and costs of sales on the face of our Consolidated
Statement of Earnings. At that time, we provided additional information to the Staff relating to
our business which has not changed substantially since 2002, and no changes were required to be
made to our financial statement presentation.

     Based on the Staff’s observations and suggestions in this Comment 6, we again reviewed and
evaluated the requirements of Regulation S-X and other existing SEC and accounting guidance
including ASC Topic 840, in each case, with a view to our current business and operations. We continue to
believe that for purposes of Rule 5-03(b)(1) of Regulation S-X, our sources of revenues are limited
to revenue from services and income from vehicle rentals. Although we agree that payments received
under traditional operating leases represent rental income (as supported by ASC Topic 840), given
that our full service lease product is primarily a service offering, we believe that our full
service lease revenue is more appropriately classified as services revenue under Regulation S-X.

     Under an integrated full service lease contract, we provide customers with vehicles,
maintenance, supplies (including fuel), ancillary services and related equipment necessary for
their operation through our network of approximately 800 maintenance facilities. Customers furnish
and supervise their own drivers, and dispatch and exercise control over the vehicles. As part of
our full service lease offering, we also provide ancillary administrative services such as
insurance, licensing, and fuel tax services. Given the various types of services that we bundle in
this arrangement, we consider full service leasing to be a service rather than a rental activity
and have aggregated this revenue with all our other service revenue in the income statement.

     We provide short-term truck rental to commercial customers to supplement their fleets during
peak periods. We do not believe that separate disclosure of commercial vehicle rental revenue is
required because it is less than 10% of consolidated revenue. We also view commercial vehicle
rental revenue as a complementary offering to our full service leasing services because
approximately 50% of commercial rentals are to existing full service lease customers.

     Given that we do not believe our revenues should be disaggregated into two activities, we
believe our current presentation of expenses on the face of the Consolidated Statement of Earnings
is consistent with Rule 5-03(b)(2) of Regulation S-X. We will, however, consistent with our response to Comment 3,
separately display maintenance and repairs expense and fuel expense on the face of the Consolidated
Statement of Earnings.

    7.

    Reference is made to note (1) on page 26 with respect to your non-GAAP operating performance
measure for “operating revenues” which 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 change in profitability from these items in certain instances. As these

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July 8, 2011

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     items are different than your other revenue producing activities and not used in evaluating
performance of the businesses and as a measure of sales activity, we suggest that you
consider separate reporting of these revenue components on the face of your Consolidated
Statements of Earnings.

    In addition, please note that separate reporting of fuel (surcharge) revenues provides a