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                             June 29, 2020

       Adam W. Miller
       Chief Financial Officer
       Knight-Swift Transportation Holdings Inc.
       20002 North 19th Avenue
       Phoenix, Arizona 85027

                                                        Re: Knight-Swift
Transportation Holdings Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2019
                                                            Response letter
dated June 18, 2020
                                                            File No. 001-35007

       Dear Mr. Miller:

              We have reviewed your June 18, 2020 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       June 8, 2020 letter.

       Form 10-K for Fiscal Year Ended December 31, 2019

       Notes to Consolidated Financial Statements
       Note 2 - Summary of Significant Accounting Policies
       Segments, page 83

   1.                                                   Your response to prior
comment 1 states that your operating segments are organized
                                                        around the types of
transportation services provided to your customers and the types of
                                                        equipment utilized in
providing those transportation services. Please tell us why the chief
                                                        operating decision
maker elects to separately analyze the operating performance of each
                                                        of the operating
segments you have identified (i.e., explain why the company is organized
                                                        in the manner that it
is).
   2.                                                   We note from your
response to prior comment 2 that nine of the nineteen operating
 Adam W. Miller
Knight-Swift Transportation Holdings Inc.
June 29, 2020
Page 2
         segments you identified met the criteria in FASB ASC 280-10-50-11 for
aggregation into
         the Trucking reportable segment. Provide us with a more detailed
analysis of your
         consideration of the aggregation criteria. For example, your response
states that the nine
         trucking operating segments provided transportation services to one
class / type of
         customer. Describe in greater detail how the needs of your customers
differ and how you
         meet those needs with your various service offerings. As part of this
analysis, tell us
         whether rate per mile from your customers, the percentage of miles for
which you are
         compensated, and the number of loaded miles you generate with your
equipment tend to
         be consistent for your service offerings.
3.       As it relates to your aggregation of the Trucking reportable segment
based on economic
         characteristics, please respond to the following:

                Tell us why you believe the Adjusted Operating Ratio, a
non-GAAP measure you
              note measures operating efficiency, is an appropriate indicator
of the economic
              characteristics of your trucking operating segments;

                Explain how you considered other metrics in analyzing whether
the aggregated
              segments have similar economic characteristics, such as the
primary indicators
              identified in your Form 10-K used to    monitor [y]our revenue
and expense
              performance and efficiency", and;

                Provide us with the historical quantitative information you
reviewed to conclude the
              nine aggregated operating segments were economically similar and
your historical
              and projected revenues and segment operating income for each of
these operating
              segments. Identify by name the nine operating segments you have
aggregated as part
              of your response.

      You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or
Ethan
Horowitz, Accounting Branch Chief, at 202-551-3311 with any questions.



FirstName LastNameAdam W. Miller                       Sincerely,
Comapany NameKnight-Swift Transportation Holdings Inc.
                                                       Division of Corporation
Finance
June 29, 2020 Page 2                                   Office of Energy &
Transportation
FirstName LastName