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Ryder System, Inc.

July 24, 2008

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-3561

    Attention:

    Joseph Foti, Senior Assistant Chief Accountant

Division of Corporation Finance

    Re:

    Ryder System, Inc.

Form 10-K for the Year Ended December 31, 2007

Form 10-Q for the Period Ended March 31, 2008

File Number: 001-04364

Ladies and Gentlemen:

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 26, 2008.
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, 2007

Notes to Consolidated Financial Statements, page 64

Note 1. Summary of Significant Accounting Policies, page 64

Revenue Recognition, page 64

    1.

    From your disclosures, it appears that your full service leasing is an all inclusive
arrangement that encompasses multiple elements, such as vehicle leasing, maintenance, supplies
and support services. However, based on your reporting and disclosures, it does not appear
that revenue of such arrangements is allocated to the respective individual elements within
each arrangement and recognized for each element. In this regard, please explain to us, with
a view to disclosing, the basis for your accounting treatment with respect to such
arrangements. Also, tell us and disclose how amounts billable for such arrangements correlate
to the respective services provided therein and the timing of when amounts due under these
arrangements are billed.

    Under a full service lease, we may provide the following deliverables:

    (1)

    Lease Deliverables (including executory costs):

    a)

    Vehicle Lease — we lease a new or used vehicle over a stated
term.

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July 24, 2008

Page 2 of 9

    b)

    Maintenance and repair services (including parts and supplies) — we
provide maintenance and repair services necessary to keep the vehicle in
service. Each vehicle must be returned to our maintenance facility for at
least 8 hours per month for preventive maintenance. In light of the
importance of maintenance to the ultimate residual value of a leased
vehicle, maintenance is a required deliverable in a full service lease
transaction. We do not lease a vehicle without Ryder-provided
maintenance.

    c)

    Insurance coverage — we may extend Ryder’s bodily injury and
property damage insurance coverage to the vehicle on behalf of the customer
during the term of the lease.

    d)

    Licensing, taxes and tax reporting — we apply and pay for
relevant licenses and taxes on a monthly, quarterly or annual basis as
required by applicable law. We gather information relating to fuel and mileage
on a daily basis and prepare and file fuel tax and mileage tax returns on a
quarterly basis.

    e)

    Periodic vehicle washing.

    (2)

    Non-Lease Deliverables:

    a)

    Substitute vehicles — we provide access to a substitute
vehicle whenever the leased vehicle has a mechanical failure which renders the
vehicle inoperable. We are not obligated to provide a substitute vehicle if
the inoperable vehicle is out of service 1) for ordinary maintenance and
service time, 2) due to driver abuse, 3) for repair of physical damage
resulting from any cause, 4) due to violation of the lease terms, 5) for
repair or maintenance of special equipment that we are not responsible for
maintaining, or 6) because it was lost or stolen.

    b)

    Emergency road service — we provide access to emergency road
service for mechanical or tire failure (unless it results from an accident,
driver abuse or violation of the lease terms).

    c)

    Safety services — we provide access to our safety programs,
including driver training, safety brochures, etc.

     The Financial Accounting Standards Board’s (FASB) Emerging Issues Task Force (EITF) Issue No.
01-8, “Determining Whether an Arrangement Contains a Lease” (EITF 01-8), provides guidance on the
accounting for multiple element arrangements that contain a lease. Paragraph 15 of EITF 01-8
requires that the classification, recognition, measurement and disclosure requirements of Statement
of Financial Accounting Standards No. 13, “Accounting for Leases” (FAS 13) be applied to the
“lease” element of the arrangement. The “lease” element (or lease deliverables) of the arrangement
represents payments and other consideration for the lease, including related executory costs and
profits thereon. Paragraph 15 of EITF 01-8 also requires that the arrangement be separated at
inception into (a) those that are for the lease deliverables, and (b) those that are for other
services (non-lease deliverables) on a relative fair value basis, consistent
with the guidance in paragraph 4(a) of EITF Issue No. 00-21, “Revenue Arrangements with
Multiple Deliverables” (EITF 00-21).

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July 24, 2008

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     Consistent with EITF 01-8, we account for the lease deliverables in a full service lease in
accordance with FAS 13. As noted above, the lease deliverables in a typical full service lease
include executory costs for maintenance, insurance and taxes. Paragraph 19(b) of FAS 13 requires
that rent be reported as income over the lease term as it becomes receivable according to the
provisions of the lease. Rent includes all contractual lease payments required to be made under the
terms of the arrangement. If the rental payments vary from a straight-line basis, income should
still be recognized on a straight-line basis unless another systematic and rational basis is more
representative of the time pattern in which use benefit from the leased property is diminished, in
which case that basis shall be used. Rental payments under our full service lease are made on a
monthly basis over the lease term. As a result, we recognize revenue on the lease deliverables
from a full service lease on a straight-line basis over the term of the lease.

     The non-lease deliverables in a typical full service lease represent less than 3% of the
arrangement on a relative fair value basis. The non-lease deliverables of the arrangement are
accounted for under EITF 00-21, which requires each unit of accounting to be separated based on
relative fair values. We recognize revenue on the non-lease deliverables on a straight-line basis
pursuant to the following guidance:

    a)

    Substitute vehicle — Access to a substitute vehicle while the leased vehicle is
undergoing repair for mechanical failure is similar to a warranty of the maintenance
services contemplated in the lease. Access to a substitute vehicle is available to our
customers every day throughout the term of the lease. As a result, straight-line is a
reasonable basis for recognition because this service is available throughout the lease
term. In addition, straight-line revenue recognition is consistent with the guiding
principles of paragraph 3 of FASB Technical Bulletin No. 90-1, “Accounting for Separately
Priced Extended Warranty and Product Maintenance Contracts” (FTB 90-1), which require that
revenue be recognized in income on a straight-line basis over the contract period except
in those circumstances in which sufficient historical evidence indicates that the costs of
performing services under the contract are incurred on other than a straight-line basis.

    b)

    Emergency road service — Access to emergency road service is also available on a
daily basis throughout the term of the lease. As a result, we also account for emergency
road service on a straight-line basis and believe it is a reasonable basis for
recognition. In addition, straight-line revenue recognition is consistent with the guiding
principles of FTB 90-1.

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July 24, 2008

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    c)

    Safety services — Customers have access to our safety programs year-round upon
request. We continually emphasize the importance of safety and incur costs (primarily a
dedicated safety organization) to maintain a high standard of safety. The safety programs
provided to our customers are an extension of our internal safety program for our drivers
and technicians. The additional cost of providing the service to our customers is
minimal. Based on the nature of costs incurred in this area, we believe it is reasonable
to recognize the revenue related to access to our safety programs on a straight-line
basis.

     In response to the last sentence of the comment, our full service lease arrangements provide
for a monthly fixed charge billing and a variable charge billing based on mileage or time usage.
Fixed charges, which do not relate to any specific deliverable, are typically billed at the
beginning of the month for the services to be provided that month. Variable charges, which do not
relate to any specific maintenance deliverable, are typically billed a month in arrears. Although
our monthly billings do not match any specific service provided during the month, the aggregate
amounts billed correlate to the performance pattern of the services provided. Amounts billed are
typically due within 10 days of the invoice date.

     Our future annual filings will expand the revenue recognition disclosures to include the
following:

     Our full service lease arrangements include lease deliverables such as the lease of a
vehicle and the executory agreement for the maintenance, insurance and taxes of the leased
equipment during the lease term and non-lease deliverables. Arrangement consideration is
allocated between lease deliverables and non-lease deliverables based on management’s best
estimate of the relative fair value of each deliverable. The arrangement consideration
allocated to lease deliverables is accounted for pursuant to Statement of Financial
Accounting Standards (SFAS) No. 13, “Accounting for Leases.” Our full service lease
arrangements provide for a fixed charge billing and a variable charge billing based on
mileage or time usage. Fixed charges are typically billed at the beginning of the month
for the services to be provided that month. Variable charges are typically billed a month
in arrears.

     Revenue from lease and rental agreements is driven by the classification of the
arrangement as either an operating or direct finance lease under SFAS No. 13. The majority
of our leases and all of our rental agreements are classified as operating leases and
therefore, we recognize lease and rental revenue on a straight-line basis as it becomes
receivable over the term of the lease or rental arrangement.

     The non-lease deliverables of our full service lease arrangements are comprised of
access to substitute vehicles, emergency road service, and safety
services. These services are available to our customers throughout the lease term.
Accordingly, revenue is recognized on a straight-line basis over the lease term.

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July 24, 2008

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    2.

    We note that you recognize revenue from maintenance service contracts on a straight line
basis over the terms of the related agreements. In this regard, describe for us, with a view
to disclosing, the typical activities performed under such contracts. Characterize for us and
in your disclosure whether each identified activity is considered to be a routine service
performed on a recurring basis or is nonroutine performed on an as needed or upon request
basis. Also, tell us if you make any distinction between maintenance and repair/overhaul
services performed under such contracts and the attribution of arrangement consideration to
each.

     Contract maintenance service revenue accounts for approximately 2% of our consolidated
revenue. Our maintenance service contract is cancelable (by either party), without penalty, after
one year with 60 days prior written notice. We may also cancel the contract earlier for specified
customer non-performance items. Under the terms of a typical vehicle maintenance service contract,
we perform the following activities:

    (1)

    Maintenance (including parts and supplies) required to keep the vehicle in
good operating condition. Each vehicle must be returned to our maintenance facility
for service and maintenance at a minimum of 8 hours each month;

    (2)

    Repairs (including parts and supplies) required to keep the vehicle in good
operating condition. We are not responsible for repair, replacement or repainting due
primarily to physical deterioration, age, use or damage or replacement of any
non-mechanical components;

    (3)

    Scheduled (at least quarterly) mechanical preventive maintenance inspections;

    (4)

    Access to emergency road service due to mechanical or tire failure (unless it
results from an accident, driver abuse or violation of lease terms); and

    (5)

    Access to a substitute vehicle for a vehicle temporarily inoperable due to
specified mechanical failure. We are not obligated to provide a substitute vehicle if
the inoperable vehicle is (a) out of service for ordinary maintenance and service time
and because of damage resulting from collision, (b) specialized, (c) of a type not
maintained in our rental fleet, or (d) out of service for repair or maintenance of
special equipment or accessories for which we are not responsible.

     The vast majority of our maintenance and repair services and all scheduled mechanical
preventive maintenance inspections are a routine service performed on a recurring basis in order to
keep a vehicle in normal operating condition. These services typically involve relatively minor
and predictable expenditures per activity. From time to time, we provide non-routine major repair
services in order to place a vehicle back in service. The costs associated with these major
non-routine services are not significant to

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the overall maintenance contract (approximately 10%). These non-routine services are not
scheduled in our service contract and are not predictable on a reliable basis (i.e. we do not have
any planned major maintenance events). In light of the infrequent and minimal nature of
non-routine services, we do not make any distinction between routine (i.e. maintenance) and
non-routine (i.e. repair / overhaul) services and do not attribute arrangement consideration to
each. Other non-routine services such as emergency road service and the provision of substitute
vehicles are access services available throughout the contract term and provided on an as needed
basis.

     Our future annual filings will disclose the typical activities performed under maintenance
service contracts as well as the routine and non-routine nature of each identified activity.
Please refer to the disclosure in response to Comment No. 3.

    3.

    Please explain to us and disclose your basis for recognizing revenue from maintenance service
contracts on a straight-line basis over the terms of the related agreements. In connection
with this and in consideration of the types of activities and their characteristics described
in the preceding comment, explain to us your consideration of recognizing arrangement
consideration as revenue on a proportional performance basis relative to the fair values of
the associated outputs in your circumstances. Also, tell us and disclose how amounts billable
for such arrangements correlate to the respective services provided therein and the timing of
when amounts due under these arrangements are billed.

     Contract maintenance service revenue accounts for approximately 2% of our consolidated
revenue. The vast majority of our maintenance and repair services and all scheduled mechanical
preventive maintenance inspections are a routine service performed on a recurring basis in order to
keep a vehicle in normal