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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,
Inc.
Form 10-K for the
Fiscal Year ended December 31, 2022
Filed February 24,
2023
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
requirements.
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
Gus
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