September 11, 2018

Jeffrey L. Taylor
Senior Vice President and Chief Financial Officer
Wabash National Corporation
1000 Sagamore Parkway South
Lafayette, Indiana 47905

       Re: Wabash National Corporation
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed February 28, 2018
           Form 10-Q for Fiscal Quarter Ended June 30, 2018
           Filed August 8, 2018
           File No. 001-10883

Dear Mr. Taylor:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 fiscal year ended December 31, 2017

Note 13: Segments, page 85

1.    You disclose the new reporting segment "Final Mile Products" implemented
during the
      fourth quarter of 2017 included other truck body activities previously
reported in the
      Commercial Trailer Products segment. However, it does not appear the
corresponding
      information for comparable prior annual periods in the Form 10-K and
interim periods
      reported in 2018 Form 10-Q's have been restated to reflect the new
composition of your
      reportable segments in accordance with ASC 280-10-50-34. Please revise as
      appropriate.
 Jeffrey L. Taylor
Wabash National Corporation
September 11, 2018
Page 2
Form 10-Q for the interim period ended June 30, 2018

Note 2: Revenue Recognition, page 7

2.       You disclose you manufacture specialty trailers, customized vans,
platform trailers, other
         transportation related equipment and products to customer
specifications. Please provide
         us with your analysis regarding how you considered whether revenue
from these
         products should be recognized over time. Refer to ASC 606-10-25-27 for
guidance.
3.       We note your disclosure that for certain performance obligations
satisfied over time
         revenue is recognized based on the measurement of actual total cost
incurred to the total
         estimated costs for each project. Please tell us, and revise to
clarify, which specific
         performance obligations you are referring to.
4.       We note in Note 2(d) in your Form 10-K for the year ended December 31,
2017 that as
         part of your used trailer trade commitments you provide residual value
guarantees. Please
         tell us your consideration of ASC 606-10-55-66 through 78 in your
treatment of these
         arrangements.
5.       It appears from your disclosures that revenue is recognized both over
time and at a point
         in time. Please tell us your consideration of disaggregating revenue
on this basis pursuant
         to ASC 606-10-50 -5.
       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 Theresa Brillant at 202-551-3307 or Doug Jones at
202-551-3309 with
any questions.



FirstName LastNameJeffrey L. Taylor                           Sincerely,
Comapany NameWabash National Corporation
                                                              Division of
Corporation Finance
September 11, 2018 Page 2                                     Office of
Transportation and Leisure
FirstName LastName