SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

February 25, 2014

Via E-mail
Alan B. Graf, Jr.
Executive Vice President and Chief Financial Officer
FedEx Corporation
942 South Shady Grove Road
Memphis, TN 38120

 Re: FedEx Corporation
  Form 10-K for the Fiscal Year Ended May 31, 2013
  Filed July 15 , 2013
  File No. 1-15829

Dear Mr. Graf:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we may
better u nderstand 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 circumsta nces, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. In your letter s to us dated  January 14, 2011 and February 4, 2011, you discussed your
contac ts with Syria and lack of contacts with Sudan, countries that are designated  by the
State Department  as state sponsors of terrorism and are subject to U.S. economic
sanctions and export controls .  We note that your website states that you currently offer
no services to or from Sudan and that services involving Syria have been suspended.  We
are aware of third party websites listing Chinese freight forwarding and shipping
companies that include your logo and purport to offer FedEx Services to Syria, Sudan
and Cuba. Cuba also is designated a state sponsor of terrorism, and is subject to U.S.
asset and export controls.

Alan B. Graf, Jr.
FedEx Corporation
February 25, 2014
Page 2

 Your Form 10 -K does not provide disclosure about the referenced countries.  Pleas e
describe to us the nature and extent of any past, current, and anticipated contacts with
Syria and Sudan since your 2011  letter s, and any contacts with Cuba, whether through
subsidiaries, freight forwarders, service contractors, distributors, affiliates,  or other direct
or indirect arrangements.  Your response should describe any services, technology,
products, equipment  or components you have provided to the  referenc ed countries,
directly or indirectly, and any agreements, commercial arrangements, or oth er contacts
with the governments of th ose countries or entities controlled by th ose governments.

2. Please discuss the materiality of any contacts with Syria, Sudan and Cuba described in
response to the foregoing comment, and whether those contacts constitu te a material
investment risk for your security holders.  You should address materiality in quantitative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent interim period .  Also, address
materiality in terms of qualitative factors that a reasonable investor would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.   Various state and municipal
governments, universities, and other investors have proposed or adopted divestment or
similar initiatives regarding investment in companies that do business with U.S. -
designated state sponsors of terrorism.  Your materiality a nalysis should address the
potential impact of the investor sentiment evidenced by such actions directed toward
companies that have operations associated with Syria, Sudan and Cuba.

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 are
in possession  of all facts relating to the 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 compan y 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 n ot 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.

Alan B. Graf, Jr.
FedEx Corporation
February 25, 2014
Page 3

 Please contact Jennifer Hardy, Special Counsel, at (202) 551 -3767 or me at (202) 551 -
3470 if you have any questions about the comments or our review.

                  Sincerely,

                  /s/ Cecilia Blye

                  Cecilia Blye, Chief
                  Office of Global Security Risk

cc:  Robert T. Molinet
  Corporate Vice President -Securities and Corporate Law

  Max Webb
  Assistant Director
 Division of Corporation Finance