United States securities and exchange commission logo

                            October 3, 2022

       James Todd
       Chief Financial Officer
       Landstar System, Inc.
       13410 Sutton Park Drive South
       Jacksonville, FL 32224

                                                        Re: Landstar System,
                                                            Form 10-K for
Fiscal Year Ended December 25, 2021
                                                            Response dated
September 13, 2022
                                                            File No. 000-21238

       Dear James Todd:

              We have reviewed your September 13, 2022 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 business days by
providing the requested
       information or advise 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
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       August 8, 2022 letter.

       Response dated September 13, 2022

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

   1.                                                   Your response to prior
comment 5 notes that "there is some unavoidable reputational risk
                                                        in operating within an
industry that depends on the use of diesel fuel." Further describe
                                                        for us how you
considered providing disclosure regarding reputational risks resulting from
                                                        operations or services
that produce greenhouse gas emissions. Include your consideration
                                                        of the potential
adverse consequences from these risks to the transportation industry in
                                                        general and to demand
for your services in particular, along with the potential risk from
                                                        climate change to
affect the perception of investors and lenders.
 James Todd
FirstName  LastNameJames Todd
Landstar System, Inc.
October    NameLandstar System, Inc.
        3, 2022
Page 2 3, 2022 Page 2
FirstName LastName
2.       We note your response to prior comment 6. Please provide us with
additional detail
         explaining how you considered providing disclosure regarding the
potential indirect
         impact to you from weather-related disruptions to your suppliers or
third-party capacity
         providers. In addition, provide us with information quantifying the
cost of property
         insurance for each of the periods for which financial statements are
presented in your
         Form 10-K.
3.       In response to prior comment 7, you state that the principal costs
associated with
         compliance with regulations focused on diesel-fuel emissions and
matters related to
         climate change are incurred by independent third-party truck capacity
         Consistent with our prior comment, provide us with quantitative
         regarding compliance costs related to climate change you incurred for
each of the periods
         covered by your Form 10-K and tell us whether increased amounts are
expected to be
         incurred in future periods.
4.       We note your response to prior comment 8. Please tell us about any
purchase or sale of
         carbon credits or offsets planned for future periods.
      Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Horowitz, Accounting Branch Chief, at (202) 551-3311 with any questions.


                                                              Division of
Corporation Finance
                                                              Office of Energy
& Transportation