SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>
[Greenbrier Logo]                              The Greenbrier Companies, Inc.

                                               One Centerpointe Drive Suite 200
                                               Lake Oswego Oregon 97035
                                               503 684 7000  Fax 503 684 7553

April 12, 2005

Mr. David R. Humphrey
Branch Chief-Accountant
Division of Corporation Finance
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C.  20549-0305

Re:  The Greenbrier Companies, Inc.
     Form 10-K for the Year Ended August 31, 2004
     File No. 001-13146
     ------------------

Dear Mr. Humphrey:

The following is in response to the comments set forth in your letter of March
23, 2005. For ease of review, the responses are in the same sequence and bear
the same numbering arrangement used in your letter.

Form 10-K for the Year Ended August 31, 2004
--------------------------------------------

Note 2 - Summary of Significant Accounting Policies
---------------------------------------------------

Inventories
-----------

   1.     We intend to provide a schedule or reconciliation of activity in the
          lower of cost or market inventory reserve for each period in which an
          income statement has been provided, as contemplated by Rule 5-04 of
          Regulation S-X. The schedule will initially be provided in the
          Form 10-K for the year ending August 31, 2005.

Maintenance Obligations
-----------------------

   2.     FTB 90-1 Accounting for separately priced extended warranty and
          product maintenance contracts states that revenue from such contracts
          should be deferred and 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. In those circumstances, revenue should be recognized over the
          contract period in proportion to the costs expected to be incurred in
          performing services under the contract.

<PAGE>

Mr. David R. Humphrey
Securities and Exchange Commission
April 12, 2005
Page 2

        We believe our accounting for maintenance contracts complies with this
        guidance. Over ninety five percent of the revenue Greenbrier earns from
        maintenance contracts is derived from "mileage-based" contracts. The
        mileage that railcars, subject to the maintenance contract, travel in a
        particular time period determines the revenue earned in that period. The
        cost incurred in providing maintenance on the railcars varies directly
        with mileage traveled. Railcars traveling a high number of miles
        generally require more maintenance than those traveling a lower number
        of miles in the same timeframe. Accordingly, revenue and margins on
        these contracts are recognized over the contract period in proportion to
        the costs expected to be incurred in performing the maintenance
        services.

Warranty Accruals
-----------------

   3.   Our response to Comment #12 in your letter of February 14, 2005
        indicated there should not be a direct relationship between revenue and
        accrued warranty balances. The reason a reader should not necessarily
        expect to see a direct correlation between revenues and the accrued
        warranty balance is that the balance is affected by reductions or
        payments as much as it is affected by additions or accruals.

        Warranties covering railcars manufactured by the Company generally
        provide for replacement or repair, at the Company's option, of defects
        due to workmanship or material for a period from three to five years
        following delivery.

        Warranty expense or additions to the warranty accruals are initially
        based on railcars produced. In North America, the amount has been $350
        per railcar for the fiscal years ended August 31, 2002, 2003 and 2004.
        The European manufacturing facility records warranty expense at 1% of
        railcar revenue. Management evaluates the warranty accrual at least
        quarterly and if the balance is not considered adequate to cover
        estimated warranty costs, an additional amount is accrued.

        Railcar deliveries in North America have accounted for approximately 80%
        of railcar revenue in the past three years. During that period, the
        North American facilities produced primarily intermodal double stack
        cars, boxcars and center partition lumber cars. Generally, boxcar prices
        are approximately 60% higher than intermodal stack cars and center
        partition lumber car prices are approximately 25% higher than intermodal
        stack cars. Unit prices can vary within each car type based on customer
        requests, competitive influence and other factors.

        As the initial warranty accrual is based on an amount per railcar, the
        production and sale of a different product mix can change the
        relationship between revenue and warranty expense in a given period.

        During fiscal 2004, approximately 63% of North American production was
        intermodal stack cars, while in fiscal 2003 and 2002 the percentage was
        closer to 50%. Center partition lumber cars accounted for approximately
        10% of deliveries in fiscal 2004, 22% in fiscal 2003 and 3% in fiscal
        2002. Boxcars accounted for approximately 10% of fiscal 2003 deliveries,
        19% in fiscal 2002 and none in fiscal 2004.

<PAGE>
        European operations produce a greater number of car types and there is
        not a readily determinable relationship of prices among the various car
        types.

        We believe the MD&A disclosures regarding the Company's manufacturing
        segment discussing product mix and prices are adequate to inform readers
        as to the reasons for fluctuations in manufacturing revenue.

If you have any further questions or comments or would like additional
clarification, please contact me at (503) 598-3815.

Sincerely,

/s/ Larry G. Brady

Larry G. Brady
Senior Vice President and
Chief Financial Officer

cc:   Kenneth D. Stephens, Tonkon Torp LLP
      David A. Gorretta, Deloitte & Touche LLP

</TEXT>
</DOCUMENT>