United States securities and exchange commission logo

                               August 29, 2023

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

                                                        Re: Landstar System,
                                                            Form 10-K for the
Fiscal Year ended December 31, 2022
                                                            Filed February 24,
                                                            File No. 000-21238

       Dear James P. Todd:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to this comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the Fiscal Year ended December 31, 2022

       Financial Statements
       Consolidated Statements of Income, page 40

   1.                                                   We note that you have
omitted the required disclosures of basic earnings per share
                                                        and details of the
underlying computations from your annual and subsequent interim
                                                        reports and expect you
will need to amend these filings to include this information.

                                                        Please revise the
Consolidated Statements of Income to include basic earnings per share
                                                        for each period, in
addition to the diluted earnings per share that is currently presented, to
                                                        comply with FASB ASC
260-10-45-2 and Rule 5-03.25 of Regulation S-X.

                                                        Please revise the notes
to the Consolidated Financial Statements to include a
                                                        reconciliation of the
numerators and denominators of the basic and diluted per-share
                                                        computations for each
period to comply with FASB ASC 260-10-50-1.
 James P. Todd
Landstar System, Inc.
August 29, 2023
Page 2
         You may refer to FASB ASC 270-10-50-1(b) and Rule 10-01(b)(2) of
Regulation S-X if
         you require further clarification or guidance on the interim reporting

         We believe that you will need to consult with your auditor regarding
changes to your
         financial statements and arrange to obtain and file an updated or dual
dated audit opinion
         that extends audit coverage to this additional information.

       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.

      You may contact Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or
Rodriguez, Staff Accountant, at (202) 551-3752 with any questions.

FirstName LastNameJames P. Todd                               Sincerely,
Comapany NameLandstar System, Inc.
                                                              Division of
Corporation Finance
August 29, 2023 Page 2                                        Office of Energy
& Transportation
FirstName LastName