SecProbe.io

Mail Stop 3561
December 16, 2016

Mr. W.M. “Rusty” Rush
President and Chief Executive Officer
Rush Enterprises, Inc.
555 I.H. 35 South, Suite 500
New Braunfels, Texas   78130

Re: Rush Enterprises, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2015
Filed February 29, 2016
File No. 000 -20797

Dear Mr. Rush :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respon d.  If you do not believe our
comment applies  to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment, we may have  additional comments.

Financial Statements and Supplementary Data

Note 18. Segments, page 73

1. It appears that your Truck reportable segment also represents a single operating segment.
Please tell us how you determined that your Truck reportable segment does not contain
multiple operating segments by addressing the following comments:

 Tell us the title and describe the role of your Chief Operating Decisio n Maker
(CODM) and each of the individuals who report to the CODM.

 Identify and describe the role of each of your segment managers.

 Tell us how often the CODM meets with his direct reports, the financial information
the CODM reviews to prepare for those meetings, the financial information discussed
in those meetings, and who else attends those meetings.

Mr. W.M. “Rusty” Rush
Rush Enterprises, Inc.
December 16, 2016
Page 2

 Tell us who is held accountable for each dealership and each relevant subset of
dealerships, such as at the brand and regional levels, along with the tit le and role of
the person each of these individuals reports to in the organization.

 Describe the information regularly provided to the CODM and how frequently it is
prepared.

 Describe the information regularly provided to the Board of Directors and how
frequently it is prepared.

 Explain how budgets are prepared, who approves the budget at each step of the
process, the level of detail discussed at each step, and the level at which the CODM
makes changes to the budget.

 Describe the level of detail communi cated to the CODM when actual results differ
from budgets and who is involved in meetings with the CODM to discuss budget -to-
actual variances.

 Describe the basis for determining the compensation for each of the individuals that
report to the CODM.

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 Sondra Snyder, Staff Accountant at  (202) 551 -3332 or Andrew Blume,
Staff Accountant at (202) 551 -3254 if you have questions regarding comment s, or me at  (202)
551-3737 with any other questions.

Sincerely,

 /s/ Jennifer Thompson

 Jennifer Thompson
 Accounting Branch Chief
Office of Consumer Products