February 23, 2021

Securities and Exchange Commission

450 5th Street, N.W.

Judiciary Plaza

Washington, D.C. 20549

Dear Sirs:

Pursuant to regulations of the Securities and Exchange Commission, submitted herewith for filing on behalf of Landstar System, Inc. is the Annual Report on Form 10-K for the period ending December 26, 2020.

During fiscal year 2020, the Company adopted the provisions of Accounting Standards Update 2016-13 – Financial Instruments-Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments.

This filing is being effected by direct transmission to the Commission’s EDGAR System.

Very truly yours,

/s/ James P. Todd

James P. Todd

Vice President and Corporate Controller

Landstar System Holdings, Inc.

JPT/kv