Mail Stop 03-05

      February 2, 2005


Via U.S. Mail

Robert E. Sigler
Chief Financial Officer
Universal Truckload Services, Inc.
11355 Stephens Road
Warren, MI  48089

Re: 	Universal Truckload Services, Inc.
	Form S-1, Amendment No. 3 filed on January 31, 2005
	File No. 333-120510

Dear Mr. Sigler,

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is 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
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      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 filing.  We look forward to working
with you in these respects and 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.

Unaudited Pro Forma Combined Statement of Income, page 28
1. We note your response to our previous comment 8a, but still
feel
the calculation of the adjustment is not readily apparent from the
explanation presented.  Specifically, from the explanation
provided,
it appears to us that the calculation should consider all
compensation paid under the consulting agreement until August 2005
as
$10,000 per month.  From the calculation provided in your
response,
however, it appears you have taken the assumed term of the
consulting
arrangement and applied that term as if it had started on January
1,
2003.  That is, your response appears to indicate that Mr. Fonzi
will
receive 12 months compensation at $10,000 per month, and $5,000
per
month for 36 months thereafter.  If our understanding of the
calculation is correct, please revise your explanation of the
terms
of the compensation package to discuss time periods (number of
months), not dates.
2. Refer to our prior comment 8b.  Please revise the
reconciliation
of pro forma average common shares outstanding in explanation (f)
on
pages 30 and 34 to include the assumed issuance price used in your
calculation.  Similar disclosure throughout your filing should
also
be revised.

* * * * *

      As appropriate, please amend the registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Amy Geddes at (202) 942-2885 or Margery
Reich
at (202) 942-1839  if you have questions regarding comments on the
financial statements and related matters.  Please contact Rolaine
Bancroft at (202) 824-5537 or me at (202) 942-2936 with any other
questions.


      Regards,


Sara W. Dunton
      Branch Chief


cc:	William B. Brentani, Esq.
      Simpson Thacher & Bartlett LLP
	via facsimile:  650-251-5002
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Robert E. Sigler
Universal Truckload Services, Inc.
Page 1