April 10, 2019

David Cobb
Vice President - Chief Financial Officer
ARCBEST Corporation
8401 McClure Drive
Fort Smith, AR 72916

       Re: ARCBEST Corporation
           Form 10-K for the Year Ended December 31, 2018
           Filed February 28, 2019
           File No. 000-19969

Dear Mr. Cobb:

       We have reviewed your filing 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-K for the Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
Asset-Light Operations
Net Revenues and Net Revenue Margin, page 52

1.     We note your presentation of ArcBest segment net revenue, a non-GAAP
measure, and
       the corresponding net revenue margin, both of which exclude purchased
transportation
       expense. We note from your disclosures on pages 62 and 83 that revenue,
purchased
       transportation expense, and third-party service expenses are reported on
a gross basis for
       certain shipments and services where you utilize a third-party carrier
for pickup, linehaul,
       delivery of freight, or performance of services but you remain primarily
responsible for
       fulfilling delivery to the customer and maintain discretion in setting
the price for the
       services. Therefore, it appears your presentation of these non-GAAP
measures substitutes
       individually tailored recognition and measurement methods for those of
GAAP. Please
 David Cobb
FirstName LastNameDavid Cobb
ARCBEST Corporation
Comapany NameARCBEST Corporation
April 10, 2019
Page 10,
April 2 2019 Page 2
FirstName LastName
         explain to us how you considered Question 100.04 of the Non-GAAP
Financial Measures
         Compliance and Disclosure Interpretations.
Adjusted Earnings Before Interest, Taxes, Depreciation, and Amortization
("Adjusted EBITDA")
Asset-Light Adjusted EBITDA, page 53

2.       We note your presentation of Asset-Light's Operating Income and the
corresponding
         reconciliation to Adjusted EBITDA. We also note you derived the
non-GAAP measures
         from aggregating ArcBest and FleetNet segment's corresponding
measures. In that
         regard, we are unclear regarding the appropriateness of the
aggregation in your
         presentation given they are different reportable segments within Note
M to the financial
         statements. Please explain.

Liquidity and Capital Resources
Cash Flow and Short-Term Investments, page 55

3.       Please quantify all variance factors cited pursuant to section 501.04
of staff's Codification
         of Financial Reporting so that investors may readily understand the
magnitude of the
         factor(s). In connection with this, you cite working capital as
contributing to the change
         in cash provided by operating activities between 2018 and 2017, but
you did not quantify
         the components of working capital in your analysis.

         After considering non-cash items when adjusting net income within the
cash flow
         statements, you disclose about $29.7 million in payments for pension
and union contract
         bonuses along with tax payments net of refunds of $3.1 million and
$4.2 million, in 2018
         and 2017, respectively, as factors behind the change. However, your
analysis did not fully
         explain the drivers behind the the total $103.4 million increase.

         Refer to section IV.B.1 of SEC Release No. 33-8350 for guidance on
clearly explaining
         how actual cash was changed by working capital components and other
factors.



        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.
 David Cobb
ARCBEST Corporation
April 10, 2019
Page 3

       You may contact Doug Jones at 202-551-3309 or Andrew Mew at 202-551-3377
if you
have questions.



FirstName LastNameDavid Cobb                          Sincerely,
Comapany NameARCBEST Corporation
                                                      Division of Corporation
Finance
April 10, 2019 Page 3                                 Office of Transportation
and Leisure
FirstName LastName