JENNIFER W. PILEGGI
CON-WAY INC.
2855 CAMPUS DRIVE, SUITE 300
SAN MATEO, CA 94403
650-378-5200




                                 January 10, 2008



VIA EDGAR

Daniel Morris
Attorney Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-3561

     RE:     Con-way Inc.
             Definitive Proxy Statement on Schedule 14A
             Filed on March 9, 2007
             File No. 001-05046

Dear Mr. Morris:

     Con-way  Inc. (the "Company") is submitting this supplemental letter  in
response to the written comments of the staff (the "Staff") of the Securities
and Exchange Commission  (the  "Commission")  contained  in your letter dated
December  10,  2007  (the "Comment Letter"), with respect to  the  Definitive
Proxy Statement on Schedule  14A  filed by the Company with the Commission on
March 9, 2007 (File No. 001-05046)  (the  "Proxy  Statement").   This  letter
responds to comment 3 of the Comment Letter.

     For  the convenience of the Staff, comment 3 from the Comment Letter  is
restated in  bold  italics prior to the Company's response. Capitalized terms
used but not defined in this letter have the meanings given to those terms in
the Proxy Statement.

3.   You have not disclosed  all  of  the necessary targets to be achieved in
     order for your executive officers  to earn their incentive compensation.
     While  we  note  your response to prior  comment  6,  causal  connection
     between the disclosure  of  all  performance targets and any competitive
     harm  is not clear. If you believe  that  certain  of  your  performance
     targets  may  be  omitted  due  to  the risk of competitive harm, please
     provide additional detailed analysis  in  support of this conclusion. We
     request that you address, with greater specificity,  how  the disclosure
     of  performance  targets  might  be  expected  to  affect the particular
     business decisions of your competitors and, in so doing,  place you at a
     competitive  disadvantage.  Refer  to  Instruction  4 of Item 402(b)  of
     Regulation  S-K.   Please  refer  to  prior  comment  6  for  additional
     guidance, as appropriate.

     RESPONSE:   In its 2008 proxy statement the Company agrees  to  disclose
     all performance  targets in accordance with Item 402(b) of Regulation S-
     K. In subsequent filings,  the  Company  will  disclose  all performance
     targets in accordance with Item 402(b) of Regulation S-K unless,  as  to
     any  performance  targets  adopted  after  the  date of this letter, the
     Company has previously provided to the Staff an analysis  acceptable  to
     the  Staff  articulating  with  specificity  how  the disclosure of such
     performance  targets  might  be  expected to place us at  a  competitive
     disadvantage. The undertaking in the  prior sentence shall not be deemed
     to  constitute  a  waiver  of the Company's  rights  under  the  federal
     securities laws, the rules of the Commission or otherwise.


                                    * * *

     If you have any questions or  comments  regarding  the foregoing or need
any additional information, please contact the undersigned at (650) 378-5326.

                                Very truly yours,

                                /s/ Jennifer W. Pileggi

                                Jennifer W. Pileggi
                                Senior Vice President, General Counsel
                                and Secretary