Mail Stop 3561

October 24, 2005


Via U.S. Mail

Mr. R. Jordan Gates
Chief Financial Officer
Expeditors International of Washington, Inc.
1015 Third Avenue, 12th Floor
Seattle Washington, 98104


	RE:	Expeditors International of Washington, Inc.
		Form 10-K for the year ended December 31, 2004
		Filed March 16, 2005
		File No. 0-13468

Dear Mr. Gates:

We have reviewed your filings and have the following comments.  We
have limited our review of your filing to those issues we have
addressed in our comments and do not intend to expand our review
to
other portions of your documents.  Where indicated, we think you
should revise your document in future filings in response to these
comments.  If you disagree, we will consider your explanation as
to
why our comments are inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filings.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.





Form 10-K for the year ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 16
Critical Accounting Estimates, page 17

1. Your critical accounting policy disclosures do not provide the
information related to the underlying estimates and judgments
required by FR-72 and SEC Release No. 33-8098.  In future filings
please expand your discussion to identify the risks associated
with
your critical accounting policies, analyzing to the extent
possible
factors such as:
* How the company arrived at the estimate;
* How accurate the estimate/assumption has been in the past;
* Whether the estimate/assumption is reasonably likely to change
in
the future; and
* Evaluate the sensitivity to change of critical accounting
policies.
For example, discuss and quantify the sensitivity of the company`s
stock compensation assumptions and the effect of reasonably
possible
changes on the company`s financial condition and operating
performance.


Liquidity and Capital Resources, page 22

2. We note your disclosures of cash used in investing activities,
including cash paid for capital expenditures.  We also note your
May
17, 2004 Form 8-K discussion of free cash flow.  Please consider
supplementing your Form 10-K disclosures to provide the amount of
capital expenditures related to expansion of your business and
those
related to maintaining your existing business activities.


Form 8-K dated November 11, 2004
Question 2

3. We note your response to question 2 indicates that when you
calculate your deferred taxes, you do so using the "tax rate that
the
entity eventually expects to pay."  Please clarify for us or in
your
filing your accounting for current and deferred taxes including
rates
that you apply.  Note that only currently enacted tax rates should
be
used in the calculations.


*    *    *    *


As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response.  Please
furnish a cover letter that keys your responses to our comments
and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your responses to our comments.

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings to be certain that the filings
include all information required under the Securities Exchange Act
of
1934 and they have provided all information investors require for
an
informed investment decision.  Since the company and its
management
are in possession of all facts relating to a company`s disclosure,
they are responsible for the accuracy and adequacy of the
disclosures
they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

You may contact Heather Tress at (202) 551-3624 or Lyn Shenk at
(202)
551-3380 if you have questions.

Sincerely,



Linda Cvrkel
Branch Chief

??

??

??

??

Mr. R. Jordan Gates
Expeditors International of Washington, Inc.
October 24, 2005
Page 1