SecProbe.io

December 2, 2014

Via E -mail
Mr. John P. Cosaert
Chief Financial  Officer
Heartland Express, Inc.
901 North Kansas Avenue
North Liberty, Iowa  52317

Re: Heartland Express, I nc.
 Form 10-K for the Fiscal Year Ended December 31 , 201 3
 Filed  March 3, 201 4
  Form 10 -Q for the Quarter Ended September 30, 2014
  Filed November 10 , 2014
 Response dated November 5, 2014
 File No. 0-15087

Dear  Mr. Cosaert :

We have reviewed your supplemental response dated November 5 , 2014 in response to
our letter dated October 22 , 2014 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 this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances or do not b elieve an amendment is
appropriate, 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 the Fiscal Year Ended December 31, 2013

Financial Stat ements
Note 1.   Significant Accounting Policies, page F -7
Segment Information, page F -7
1. We have reviewed your response to our prior comment 1.  We note that the Vice
President of Sales, Vice President of Operations, Vice President of Regional Operations,
and Chief Operating Officer – GTI each report directly to the CEO.   Please tell us:

John P. Cosaert
Heartland Express, Inc.
December 2 , 2014
Page 2

  The scope of each individual’s responsibilities (e.g., entire entity or certain
divisions within the entity).
 The nature of their responsibilities.
 The nature of the informa tion and the level of detail conveyed to the CEO in
each individual’s discussions with the CEO.
 How their compensation is determined (e.g., fixed salary, bonus contingent
upon performance of entire entity, bonus contingent upon performance of
certain div isions).
 The positions that report to each of these individuals.

2. Please identify your operating segments that you aggregate into one reportable
segment.   In this regard:

a. Your disclosures in note 1 refer to “regional operating divisions.”   Please identify for
us each of your regional operating divisions and clarify whether they represent your
operating segments.

b. Your response refers to “three truckload transportation services.”   Please identify for
us each service and, if different from   your regi onal operating divisions, clarify
whether they represent your operating segments.

3. As requested, please advise us of the amount of revenues and operating profit for GTI for
the period of November 11, 2013, date of acquisition, through December 31, 2013, an d
for the nine months ended September 30, 2014.   Provide a breakdown of revenues by
type of service, that is, dry -van truckload services, asset based temperature -controlled
truckload operations, and freight brokerage services.

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 rules require.   Since the company and its management ar e
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.

John P. Cosaert
Heartland Express, Inc.
December 2 , 2014
Page 3

 You may contact Beverly A. Singleton at (202) 551 -3328 or Claire L. Erlanger  at (202)
551-3301 if you have questions regarding comments on the financial statements and related
matters.  Please contact me at (202) 551 -3750 with any other questions.

Sincerely,

 /s/ Andrew Mew

Andrew Mew
Senior Assistant Chief Accountant