SecProbe.io

Mail Stop 3561
February 2, 2017

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
Response dated January 18, 2017
File No. 000 -20797

Dear Mr. Rush :

We have reviewed  your January 18, 2017 response to our comment letter 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 busine ss days by providing the requested
information or advis e 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.
Unless we note otherwise, our references to prior comments are to comments in our December
16, 2016  letter .

Financial Statements and Supplementary Data

Note 18. Segments, page 73

1. We note your response to comment 1.  In order to assist us in evaluating your response
and your disclosures, please provide the follo wing information:

 We note that your CODM reviews monthly and daily trend reports of multiple
metrics.  Please explain in reasonable detail the specific metrics he reviews and how
he utilizes this information.

 We note that you have Senior Vice Preside nts who report directly to your CODM for
each of your (1) Parts, Service and Body Shop, (2) Finance, Insurance and Leasing
and (3) Retail Sales and Marketing operations.  We also note that your CODM

Mr. W.M. “Rusty” Rush
Rush Enterprises, Inc.
February 2, 2017
Page 2

 reviews certain financial information, including monthly unit sales and gross profit
for vehicle sales and daily gross profit on parts service and body shop sales, prior to
his monthly one -on-one meetings with these individuals and that each of these
individuals discusses “the overall operations of the dealershi p network that they
oversee.”  Please tell us  the nature of the specific dealership operations each of these
individuals discusses with the CODM in their separate monthly meetings.  For
example, clarify if the Senior Vice President for Parts, Service and B ody Shop
operations discusses overall operations of the dealership network, including the
Finance, Insurance and Leasing and Retail Sales and Marketing operations, or
primarily just the operations he is directly responsible for managing.  Also tell us
whet her each of these individuals discusses any financial information of the
dealership network with the CODM and if so, describe to us the specific financial
information each discusses.

 We note that upon receipt of the consolidated budget, your CODM meets with his
direct reports to discuss the budgets for the corporate departments they manage and
either approves the budgets or suggests revisions.  Please define “corporate
departments” for  us and tell us what type of departmental level detail is included in
the consolidated budget provided to the CODM.  If budget information below a
consolidated level is included, please tell us what type of information is provided for
each corporate depart ment.  As part of your response, please specifically tell us
whether your CODM receives, discusses and/or approves budget information for each
of your (1) Parts, Service and Body Shop, (2) Finance, Insurance and Leasing and (3)
Retail Sales and Marketing operations and, if applicab le, discuss the specific budget
information he receives.

 Please tell us whether your CODM receives and utilizes any other financial
information related to your (1) Parts, Service and Body Shop, (2) Finance, Insurance
and Leasing and (3) Retail Sales and Market ing operations when assessing
performance and allocating resources and how you considered whether any of these
operations may represent separate operating segments.

2. We note your statement that the key metric your CODM utilizes to review performance
and allo cate resources is operating income on a consolidated basis.  However, we note
that you do not present a segment measure for operating income but, rather, present
segment income (loss) from continuing operations before taxes, which appears to
represent the line item captioned “Income before taxes” on your consolidated statements
of operations.  Please explain why you do not appear to disclose a segment measure for
operating income.  Please refer to ASC 280 -10-50-22.

Mr. W.M. “Rusty” Rush
Rush Enterprises, Inc.
February 2, 2017
Page 3

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