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CORRESP
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corresp

February 8, 2005

VIA EDGAR AND FACSIMILE (202)942-9527

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, DC 20549

Attention: Sara W. Dunton and Rolaine S. Bancroft

         Re:

    UNIVERSAL TRUCKLOAD SERVICES, INC.

Registration Statement on Form S-1, as amended (File No. 333-120510)

Dear Ladies & Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), the
undersigned, as representative of the prospective underwriters of the proposed public offering (the
"Offering”) of common stock of Universal Truckload Services, Inc. (the “Company”), hereby join in
the Company’s request that the effective date for the above-referenced Registration Statement be
accelerated so that it may become effective at 4:30 p.m., Washington D.C. time, on Thursday,
February 10, 2005, or as soon thereafter as is practicable.

     In accordance with Rule 460 under the Securities Act, and in connection with the foregoing,
please note that the undersigned have effected from January 31, 2005, through the date hereof
approximately the following distribution of copies of the preliminary prospectus dated January 31,
2005, as filed with the Securities and Exchange Commission:

    To Whom Distributed
    Number of Copies

    Prospective Underwriters

    4,957

    Institutions and Individuals

    1,137

    Other

    7

    Total

    6,101

     The undersigned confirm that they have complied with and will continue to comply with, and
that they have been informed by participating underwriters and dealers that they have complied with
and will continue to comply with, Rule 15c2-8 under the Securities Exchange Act of 1934, as
amended, in connection with the Offering.

    Very truly yours,

    STEPHENS INC.

    As representative of the several underwriters

    By:    STEPHENS INC.

    By: /s/ Gary S. Ciuba

    Name: Gary S. Ciuba

Title: Managing Director

February 8, 2005

VIA EDGAR & FACSIMILE (202-942-9527)

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, D.C. 20549

Attention: Sara W. Dunton and Rolaine S. Bancroft

    Re:

    Universal Truckload Services, Inc.

Registration Statement on Form S-1, as amended (File No. 333-120510)

Ladies and Gentlemen:

     Universal Truckload Services, Inc. (the “Company”) respectfully requests, pursuant to Rule 461
of the General Rules and Regulations of the Securities Act of 1933, as amended, that the
above-referenced Registration Statement on Form S-1, along with the Company’s related Registration
Statement on Form 8-A (File No. 000-51142), be declared effective by the Securities and Exchange
Commission (the “Commission”) at 4:30 p.m., Washington, D.C. time, on February 10, 2005, or as soon
thereafter as is practicable.

     The Company acknowledges that should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing; the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not relieve the Company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and the Company may
not assert this action as a defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

    Very truly yours,

    Universal Truckload Services, Inc.

    /s/ Robert E. Sigler

    Robert E. Sigler

Vice President and Chief Financial Officer