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SEC Response Letter

 November 10,
2005

 Via EDGAR Submission

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention: Joe Foti

Re:
Old Dominion Freight Line, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2004

File No. 000-19582

 Ladies and Gentlemen:

 This
letter is submitted in response to comments contained in the letter dated October 14, 2005 from Joe Foti of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) to Earl E. Congdon, the Chief
Executive Officer of Old Dominion Freight Line, Inc. (the “Company”) regarding the Company’s Form 10-K for the fiscal year ended December 31, 2004 (the “Form 10-K”).

 The comments and responses set forth below are keyed to the numbering of the
comments and the headings used in the Staff’s October 14, 2005 letter. Where appropriate, the Company has responded to the Staff’s comments by proposing changes to the disclosure in the Form 10-K, which would be filed as an amendment
to the Form 10-K (the “Form 10-K/A”). Page numbers referred to in the responses below reference the applicable pages of the Form 10-K. Capitalized terms used but not otherwise defined herein have the meanings given them in the Form 10-K.

 Form 10-K for the Fiscal Year Ended December 31, 2004

Item 7.
Management’s Discussion and Analysis of Financial Condition and Results of Operations

 MD&A – Results of Operations, pages 17-21

 Consolidated Statements of Operations, page 29

 Comment 1: From your disclosure in the narrative section of MD&A, we note the amounts of “fuel surcharge” revenues materially vary from period-to-period from a range of approximately $17
million in 2002 to $53 million in 2004. Consistent with the reporting treatment presented by other industry (trucking) registrants, we believe you should separately classify these other miscellaneous revenues from your “base” revenues on
the face of the consolidated statements of operations. In this regard, there would be two (2) separate captions such as “revenues, before fuel surcharge” and “fuel surcharge revenues” with a subtotal amount for total
revenues. In addition, the MD&A should parallel the consistent treatment in the consolidated financial statements by providing a breakdown of total revenues into these two components with a separate discussion of each component. We believe this
will afford easier analysis with clearer and more transparent disclosure for investors. Please revise accordingly.

 Response 1: Regulation S-X, Article 5, Rule 5-03(b) states that “If income is derived from more than one of the
subcaptions described under Rule 5-03.1, each class which is not more than 10 percent of the sum of the items may be combined with another class.” We derive our income from only one of these subcaptions, which is “revenue from
services” through the freight delivery services provided to our customers. There are over 55 components, including a fuel surcharge, that could be included in the rating of each freight shipment. Examples of other components that could be
included on a single freight invoice are charges for inside deliveries, freight arrival notifications, port security charges and region surcharges. These various components constitute the overall charge for delivering a shipment and are not billed
separately. Accordingly, we respectfully submit that we are in compliance with Rule 5-03(b) of Regulation S-X and that fuel surcharges need not be separately presented in our statements of operations.

 Additionally, none of our principal competitors in the less-than-truckload (LTL) industry
discloses this information. Our principal competitors include: Yellow Roadway Corp., Arkansas Best Corp., CNF, Inc., SCS Transportation, Inc., Central Freight Lines Inc., Overnite Corp. (acquired by United Parcel Service, Inc. in 2005) and USF Corp.
(acquired by Yellow Roadway in 2005).

 Historically, fuel and other cost
factors are considered when transportation companies establish their base rates. Generally, fuel surcharges are applied only when extreme increases in fuel prices in a relatively short time frame make it impracticable for transportation companies to
update their base rates. In addition, these surcharges have historically been relatively temporary in nature or are ultimately included as increases in base rates as prices stabilize. As a result, separate line item disclosure and period comparison
could be misleading when this transition from surcharge to base rate occurs.

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 To provide readers with information concerning our fuel surcharge, we do provide a discussion in the third paragraph of
the “2004 Compared to 2003” section of MD&A on page 18.

 Critical Accounting Policies

 Allowance for
Uncollectible Accounts, page 24

 Comment 2:
We note that your customer receivables balance in 2004 compared to 2003 materially increased by 30%, while your allowance for uncollectible accounts only increased 10%. We also note that approximately 74% of your total current assets balance at 2004
is comprised of customer receivables. Considering the significance of the above mentioned fluctuations, and the fact that you consider your allowance of uncollectible customer accounts as one of your critical accounting policies, we believe your
MD&A should discuss the facts and circumstance as to why your allowance of uncollectible accounts did not increase proportionally in relation to the increase in your customer receivable balance between 2003 and 2004. Additionally, please enhance
your MD&A and discuss the factors as to how you arrived at the estimate of your allowance for uncollectible accounts, how accurate the estimate/assumption has been in the past, how much the estimate/assumptions has changed in the past and
whether the estimate/assumptions is reasonably likely to change in the future. See FR-72 for guidance.

 Response 2: The 29.4% increase in our customer receivables balance at year-end 2004 was a direct result of the 28.8%
revenue growth we experienced in the fourth quarter of 2004 when compared to the fourth quarter of 2003. For the comparable months of December, revenue increased 32.4% in 2004 versus 2003.

 To establish our allowance for uncollectible accounts, we utilize a model that stratifies our
customer accounts receivable by age and by internally defined receivable groupings. We have developed historical predictive factors of bad debt for each group and age of the receivable, which we use to calculate our estimate. In our experience,
current accounts receivable generally require a smaller bad debt reserve, while aged accounts receivable are more at risk of not being paid and require a higher bad debt reserve. We also consider specific customer information and recent trends in
our customer base.

 Our allowance for uncollectible accounts increased 12.2% at
year-end 2004 compared to 2003. This increase does not track our overall increase in customer accounts receivable because of improvements in 2004 in both the aging of our customer receivables and a reduction in the amount of customer receivables
assigned to third-party collection agencies that historically have resulted in higher bad debt experience. Our “improvements in aging” are attributable to the significant increase in our revenue growth in the fourth quarter of 2004, which
resulted in an increase in current accounts receivable that historically are more likely to be paid than aged accounts receivable.

 The factors in our model were developed using our actual experience and we have found these factors to be accurate. We plan to continue to use this model and periodically
we will validate the predictive factors based on our current experience.

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 In the Form 10-K/A, we propose to revise our disclosure in the “Critical Accounting Policies – Allowances for
Uncollectible Accounts and Revenue Adjustments” section of our MD&A to provide additional information on the reserve as set forth below.

 Allowances for Uncollectible Accounts and Revenue Adjustments - We maintain an allowance for uncollectible accounts for estimated losses
resulting from the inability of our customers to make required payments. We estimate this allowance by analyzing the aging of our customer receivables, our historical loss experience and other trends and factors affecting the credit risk of our
customers. Actual write-offs could differ from our allowance estimate as a result of several factors including changes in the overall economic environment or factors and risks surrounding our customers. Additional allowances may be required if the
financial condition of our customers were to deteriorate, resulting in an impairment of their ability to make payments. We continually review the underlying assumptions in our estimate of the allowance for uncollectible accounts so as to reflect the
most recent trends and factors.

 We also maintain an allowance
for revenue adjustments resulting from billing corrections, customer allowances, money-back service guarantees and other miscellaneous revenue adjustments. These revenue adjustments are recorded in our revenue from operations. We use historical
experience, trends and current information to update and evaluate these estimates.

 Management believes the methodologies for estimating these allowances to be reliable based on the accuracy of our estimate in prior periods. As such, we do not anticipate any near-term changes in our methodologies for
these estimates.

Item 8.
Financial Statements and Supplementary Data

 Note 1. Significant Accounting Policies

 Segments, page 32

 Comment 3: We note from your disclosure in your business section on page 2 of your filing that you currently have four branded product groups,
OD-Domestic, OD-Expedited, OD-Global, and OD-Technology and that you also provide international services around the globe. In this regard, please revise your filing to include and provide us with the disclosures required by paragraphs 37 and 38 of
SFAS No. 131. If providing this information is impracticable, please provide us with your detailed reason(s) for this fact.

 Response 3: Our Company provides transportation services and/or solutions to our customers through one operating segment and one
management team, which distinguishes us from our principal competitors. We have, however, found it advantageous to market our basic transportation services with the OD-Domestic, OD-Global, OD-Expedited or OD-Technology brands to focus on specific
customer needs and to highlight our operational capabilities in the

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marketplace. All of our assets and infrastructure are in located in the United States and essentially all of the transportation services that we directly
provide, and the revenue derived from those services, are domestic. We market our OD-Global brand to provide our customers the capability to ship to and from foreign countries through our alliance with other transportation companies that physically
move their shipments outside the United States. Our OD-Expedited brand is our marketing concept for expedited or time-sensitive shipments, which are physically moved on our domestic transportation system, typically on the same trucks and schedules
that are used for all of our domestic deliveries. Our OD-Technology brand is the software and systems that we provide our customers at no cost to track shipments and access account information; therefore, no revenue is associated with this brand.

 Because of these factors, we do not believe classifying revenues by product
group is practical or would be of significant value in our disclosures. In our review of our principal competitors’ filings with the SEC, we note that all domestic LTL services are generally combined into one product group, consistent with our
current disclosure.

 We can estimate geographical revenue based upon
information contained in our freight billing system; however, we believe the information is immaterial and would not be of significant value in our disclosures. For the Staff’s information, our revenue from operations from shipments with an
origin or destination outside the United States is estimated at $6,726,000, $3,812,000 and $3,689,000 in 2004, 2003 and 2002, respectively, and is largely derived from Canada and Mexico.

 Revenue and Expense Recognition, page 32

 Comment 4: Please tell us and expand your disclosure to explain how you account for billing adjustments,
discounts, money-back service guarantees and billing corrections. We may have further comment upon receipt of your response.

 Response 4: Based upon information we obtain when we receive customer shipments, we assign a rate that is based upon
the general classification of the product, weight, individual customer pricing, point of origin and destination, as well as other factors. Adjustments to these original rates are recorded in revenue from operations and typically occur when we
receive additional information that changes one of the factors that was used in the original rating of the shipment. For example, reweigh adjustments to original freight bills are common for discrepancies between the actual weight of customer
shipments and the weight estimates provided by our customers. Revenue adjustments also result from cumulative customer volume allowances, customer loading and unloading allowances, our failure to perform guaranteed services and for various
miscellaneous reasons. We reserve for future revenue adjustments based upon historical experience, specific customer information, trends and other available current information.

 As requested, in the Form 10-K/A we will expand the discussion of revenue adjustments in the “Critical Accounting Policies –
Allowances for Uncollectible Accounts and Revenue Adjustments” section of our MD&A, as set forth in our response to Comment # 2 above, and in

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“Note 1. Significant Accounting Policies – Allowances for Uncollectible Accounts and Revenue Adjustments”, which would mirror our response to
Comment #2 above.

 Accounting Policies (Tires on Equipment), page 33

 Comment 5: It is unclear as to the nature
of the items included in the cost of “Tires on Equipment” and “Revenue Equipment” classified as current and non-current (property and equipment), respectively, on the consolidated balance sheet. Your significant accounting
policies should address how you specifically account for the cost incurred for each of the following items: (i) original tires acquired with revenue equipment; (ii) replacement tires; and (iii) recapping tires. Please tell us and
clarify the disclosure in your accounting policy to address each of these items, accordingly.

 Response 5: “Tires on Equipment” on our balance sheet refers to all new, used and recapped tires that are
mounted on our rolling stock assets, which include tractors, trucks, trailers and dollies. We amortize these tires over their estimated useful life and periodically compare and adjust the value in the “Tires on Equipment” account to a
model that calculates the value of these tires using actual equipment counts and assumptions built from physical inventories. We periodically validate the assumptions used in our model by evaluating equipment moving through one of our larger service
centers to determine the percentage of equipment with new and recapped tires and by measuring the percentage of tread remaining on the tires. Tires that have been purchased but not mounted are recorded at cost in “Prepaid Expenses”.

 In the Form 10-K/A, we will clarify our disclosure to address these items as
set forth below:

 Tires on Equipment

 The cost of original and replacement tires mounted on equipment is
recorded in tires on equipment and amortized based on usage determined by periodic samplings of tread depth.

 Note 3 – Leases, page 36

 Comment 6: As your disclosure on leases is brief, it is unclear whether your revenue equipment leases provide for guarantees by the re