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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,
Inc.
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
additional
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
22
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.
Comapany
October NameLandstar System, Inc.
3, 2022
October
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
providers.
Consistent with our prior comment, provide us with quantitative
information
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
Ethan
Horowitz, Accounting Branch Chief, at (202) 551-3311 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Energy
& Transportation