EXPDExpeditors International

Refer to the graph titled "Absolute Pay vs TSR Alignment." The vertical bars identified as CEO Compensation Actually Paid and NEO Average Compensation Actually Paid appear to reflect the Summary Compensation Table amounts, rather Compensation Actually Paid amounts.

Rest of the question

In addition, it is not clear why the title of the graph refers to “Absolute Pay,” or why such title refers to TSR but not to “Operating Income,” which is also included in the graph. The requirement of Items 402(v)(5)(i) and (iii) is to describe the relationship between compensation actually paid and total shareholder return, and compensation actually paid and the Company-Selected Measure, respectively. Please ensure that the disclosures provided pursuant to Regulation S-K Item 402(v)(5) reflect the correct amounts and terminology from the pay versus performance table.

I am writing to confirm that Expeditors International of Washington, Inc. will revise its future proxy disclosures on Pay versus Performance in accordance with your comments set forth in your letter to us dated July 28, 2023. If you should have any further questions or comments, please do not hesitate to contact me at (206) 674-3412. One letter for all the questions, without numbered answers. Read the reply ↗

Please provide a clear description of the relationship between compensation actually paid and net income, as required by Regulation S-K Item 402(v)(5)(ii).

See the reply above.