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December 9, 2022
Eric Marchetto
Chief Financial Officer
Trinity Industries, Inc.
14221 N. Dallas Parkway, Suite 1100
Dallas, Texas 75254-2957
Re:Trinity Industries, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed February 17, 2022
Form 8-K furnished October 25, 2022
File No. 001-06903
Dear Eric Marchetto:
            We have limited our review of your filing to the financial statements and related
disclosures 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 8-K furnished October 25, 2022
Exhibit 99.1 Earnings Release, page 1
1.We note that you disclose the Future Lease Rate Differential (“FLRD”) at the end of the
three month period ended September 30, 2022 as well as at the end of the three month
period ended September 30, 2021.  We also note your disclosure that FLRD calculates the
implied change in revenue for railcar leases expiring over the next four quarters, assuming
they were renewed at the most recent quarterly transacted lease rates for each railcar type.
Please explain to us and consider revising future filings to disclose the reasons why the
metric is useful to investors, how management uses the metric, and if there are estimates
or assumptions underlying the metric or its calculation, include disclosure of such items if
it’s necessary for the metric not to be misleading. For reference, see guidance in SEC
Release No. 33-10751 Commission Guidance on Management’s Discussion and Analysis
of Financial Condition and Results of Operations.

 FirstName LastNameEric Marchetto
 Comapany NameTrinity Industries, Inc.
 December 9, 2022 Page 2
 FirstName LastName
Eric Marchetto
Trinity Industries, Inc.
December 9, 2022
Page 2
Form 10-K for the Fiscal Year Ended December 31, 2021
Free Cash Flow, page 53
2.In your determination of “Adjusted Net Cash Provided by Operating Activities”, you
adjust for proceeds from lease portfolio sales, which is presented in investing activities.
Please tell us how you determined that this adjustment does not result in a non-GAAP
measure based on individually tailored accounting principles. Refer to the guidance in
Question 100.04 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.
3.Your calculation of “Free Cash Flow” differs from the typical calculation of this measure
(i.e., cash flows from operations less capital expenditures). In order to avoid potential
confusion, in future filings, earnings releases, and investor presentations, please revise the
title to “Adjusted Free Cash Flow After Investments and Dividends” and the definition of
your non-GAAP measure to “Adjusted Free Cash Flow” or a similar title. Refer to
Question 102.07 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial Measures.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Eiko Yaoita Pyles, Staff Accountant, at 202-551-3587 or Claire
Erlanger, Senior Staff Accountant, at 202-551-3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing