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 May 4, 2026

Leah Stearns
Chief Financial Officer
Copart, Inc.
14185 Dallas Parkway Suite 300
Dallas Texas 75254

 Re: Copart, Inc.
 Form 10-K for the Fiscal Year Ended July 31, 2025
 File No. 000-23255
Dear Leah Stearns:

 We have completed our review of your filing. 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.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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CORRESP
 1
 filename1.htm

 CORRESP

 April 23, 2026
 VIA EDGAR Securities and Exchange Commission
 Commission Division of Corporation Finance Office of
Trade & Services 100 F Street, N.E. Washington,
D.C. 20549 Attention:

 Re:
 Copart, Inc.
 Form 10-K for the Fiscal Year Ended July 31, 2025
 Filed September 26, 2025
 File No. 000-23255 Ladies and Gentlemen:
 Copart, Inc. (the “ Company ”) submits this letter in response to comments from the staff (the
“ Staff ”) of the Securities and Exchange Commission (the “ Commission ”) received by letter dated April 14, 2026, relating to the Company’s
 Form 10-K for the fiscal year ended July 31, 2025 (File No. 000-23255) originally filed with the Commission on September 26, 2025.
 In this letter, the comments from the Staff have been reproduced in italicized, bold type, and are followed by the Company’s
response. Form 10-K for the Fiscal Year Ended July 31, 2025
 Index to Consolidated Financial Statements Note 14.
Segments and other Geographic Reporting, page 80

 1.
 Please tell us how your disclosure complies with the requirement to disclose how the chief operating
decision maker uses your reported measures of segment profit or loss in assessing segment performance and deciding how to allocate resources pursuant to ASC 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance.
 The Company respectfully acknowledges the Staff’s comment and the requirements of ASC 280-10-50-29.f and the illustrative guidance in ASC 280-10-55-47.bb. In response to the Staff’s comment, the Company proposes to
enhance its segment disclosure in future periodic filings to explicitly describe how the CODM utilizes these measures. Specifically, the CODM uses Operating Income by segment to evaluate the operational efficiency of each segment, and determine the
allocation of capital for land acquisitions and infrastructure improvements.

 The Company intends to include the following (or substantially similar) language in the
segment footnote of its future filings: “The Company’s CODM evaluates the performance of its reportable segments and
allocates resources based on segment Operating Income. This measure is used to assess profitability, guide decisions regarding capital investment, and evaluate the performance of segment leadership.”

 2.
 Please confirm that the expenses presented are the significant segment expenses provided to your chief
decision maker, and consider labeling the expenses as significant segment expenses or other segment items. See ASC
 280-10-50-26A and 26B.
 The Company acknowledges the Staff’s comment and confirms that the expenses presented in the segment footnote represent the significant
segment expenses provided to, and utilized by, the CODM in accordance with ASC 280-10-50-26A and 26B.
 To address the Staff’s objective of providing clearer disclosure, the Company proposes to clarify in the narrative text of the segment
footnote in future filings that these specific line items represent the significant segment expenses reviewed by the CODM. The Company
intends to include the following (or substantially similar) language in the segment footnote of its future filings: “The specific line items in
the tables represent the significant segment expenses reviewed by the CODM.”

 Very truly yours

 /s/ Leah C. Stearns

 Leah C. Stearns

 Senior Vice President and Chief Financial Officer

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 April 14, 2026

Leah Stearns
Chief Financial Officer
Copart, Inc.
14185 Dallas Parkway Suite 300
Dallas Texas 75254

 Re: Copart, Inc.
 Form 10-K for the Fiscal Year Ended July 31, 2025
 File No. 000-23255
Dear Leah Stearns:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended July 31, 2025
Index to Consolidated Financial Statements
Note 14. Segments and Other Geographic Reporting, page 80

1. Please tell us how your disclosure complies with the requirement to
disclose how the
 chief operating decision maker uses your reported measures of segment
profit or loss in
 assessing segment performance and deciding how to allocate resources
pursuant to ASC
 280-10-50-29.f. Refer to ASC 280-10-55-47.bb for guidance.
2. Please confirm that the expenses presented are the significant segment
expenses provided
 to your chief decision maker, and consider labeling the expenses as
significant segment
 expenses or other segment items. See ASC 280-10-50-26A and 26B.
 April 14, 2026
Page 2

 In closing, 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.

 Please contact Aamira Chaudhry at 202-551-3389 or Theresa Brillant at
202-551-3307
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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