SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

        September 1 2, 2014

Via E-mail
Alan B. Graf, Jr.
Chief Financial Officer
Fedex Corporation
942 South Shady Grove Road
Memphis, Tennessee 38120

Re: Fedex Corporation
 Form 10-K for the Fiscal Year Ended May 31, 201 4
Filed  July 14 , 2014
 File No.  001-15829

Dear Mr. Graf:

We have reviewed your filings 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 letter within ten business days by confirming that you will revise
your document in future filings and by prov iding any requested information .  If you do not
believe our comment appl ies to your facts and circumstances, please tell us why in your
response.

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

Form 10 -K

Management’s Discussion and Analysis of Results of Operations and Financial Condition, page
36

Results of Operations, page 37

Operating Income, page 41

1. We note that despite an overall decrease in fuel expense and a lower jet fuel price per
gallon, fuel  expense had a significant negative impact on your operating income in fiscal
2014.  Please revise to disclose further details concerning the static analysis that

Alan B. Graf, Jr.
Fedex Corporation
September 1 2, 2014
Page 2

 compares the year -over-year changes in fuel prices and surcharges that explain in further
detail how these changes negatively impacted your operating income in fiscal 2014.  In
this regard, stating that you perform a static analysis that reveals a negative impact while
fuel expense actually decreased in fiscal 2014 is confusing to an investor.  Pl ease revise
accordingly.  Your discussion of your operating results for your segments should be
similarly revised where applicable.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that t he 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 a company’s disclosure, they are responsible for the accu racy
and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement
from the company acknowledging that:

 the company 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 not 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.

You may contact Heather Clark at 202 -551-3624  if you have questions regarding
comments on the financial statements and related matters.  Please contact me at 202 -551-3813
with any other questions.

Sincerely,

 /s/ Linda Cvrkel

 Linda Cvrkel
Branch Chief