December 9, 2019

Robert Sanchez
Chairman and Chief Executive Officer
Ryder Sytem, Inc.
11690 N.W. 105th Street
Miami, FL 33178

       Re: Ryder Sytem, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Filed February 21, 2019
           Form 10-Q for the Fiscal Quarter Ended September 30, 2019
           Filed October 30, 2019
           File No. 001-04364

Dear Mr. Sanchez:

       We have reviewed your filings 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.

Form 10-Q for the Fiscal Quarter Ended September 30, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Operating Results by Business Segment
Fleet Management Solutions, page 45

1.    We note the substantially reduced EBT for the FMS segment for each
current year period
      presented relative to the corresponding prior year period, including a
significant loss for
      the three months ended September 30, 2019. You attribute the reduced
results to higher
      depreciation resulting from changes in used vehicle residual value
estimates made in the
      third quarter 2019 and higher losses from used vehicle sales resulting
from higher residual
      value adjustments and lower expected sales prices and volumes. In
correlation with your
      disclosure in "Critical Accounting Estimates" in regard to these items,
please expand your
      discussion of how this trend regarding residual values, depreciation, and
deteriorating
 Robert Sanchez
Ryder Sytem, Inc.
December 9, 2019
Page 2
      market conditions for used vehicles is expected to impact future FMS EBT
in annual and
      interim reporting periods. Refer to Item 303(a)(3)(ii) and the
introductory paragraph to
      Item 303(b) of Regulation S-K. To the extent appropriate and material,
expand your
      disclosure regarding the above noted trend to the DTS and SCS segments.
Financial Resources and Liquidity, page 51

2.    Please provide a more robust analysis of the lower working capital needs
contributing to
      the nearly 25% increase in net cash provided by operating activities in
the current interim
      period compared to the corresponding prior year period. Your analysis
should explain the
      reason for the lower working capital needs, and address each working
capital item
      materially contributing to the change and the underlying drivers
associated with each.
      Refer to section IV.B.1 of SEC Release No. 33-8350 for guidance.
        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 Robert Shapiro, Senior Staff Accountant, at
202-551-3273 or Doug
Jones, Senior Staff Accountant, at 202-551-3309 if you have questions regarding
comments on
the financial statements and related matters.



                                                           Sincerely,
FirstName LastNameRobert Sanchez
                                                           Division of
Corporation Finance
Comapany NameRyder Sytem, Inc.
                                                           Office of Trade &
Services
December 9, 2019 Page 2
cc:       Scott Parker
FirstName LastName