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                             December 14, 2020

       Michael Zechmeister
       Chief Financial Officer
       C. H. Robinson Worldwide, Inc.
       14701 Charlson Road
       Eden Prairie, Minnesota 55347

                                                        Re: C. H. Robinson
Worldwide, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2019
                                                            Filed February 19,
2020
                                                            File No. 000-23189

       Dear Mr. Zechmeister:

              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 Fiscal Year Ended December 31, 2019

       Management's Discussion and Analysis, page 23

   1.                                                   We note your
presentation of the non-GAAP measure net revenues. Given that this
                                                        measure reduces your
reported revenue by a non-revenue line item, explain to us your
                                                        basis for presenting
this as a measure of revenue. If net revenues is intended to be
                                                        presented as a measure
of gross profit, tell us whether and, if so, how you considered the
                                                        use of a different
caption and the presentation of a reconciliation for this non-GAAP
                                                        measure to the most
directly comparable GAAP measures, i.e. gross margin that includes
                                                        depreciation, depletion
and amortization. See Item 10(e)(1)(i)(B) of Regulation S-K.
   2.                                                   We note that you
disclose operating margin at page 24 which appears to be calculated by
                                                        dividing operating
income by net revenues, a non-GAAP measure. Please identify
                                                        operating margin as a
non-GAAP measure and provide the applicable disclosures under
                                                        Item 10(e) of
Regulation S-K or tell us why you believe these disclosures are not
                                                        necessary.
 Michael Zechmeister
C. H. Robinson Worldwide, Inc.
December 14, 2020
Page 2
Note 9: Segment Reporting, page 57

3.       We note that you disclose net revenues and income (loss) from
operations in your segment
         footnote. Please tell us if both of these measures are used by the
CODM as the measure of
         segment profit or loss in assessing performance and deciding how to
allocate resources
         and how you have considered the guidance in ASC 280-10-50-28 in
determining the
         appropriate measure to disclose.
        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 Steve Lo at 202-551-3394 or Craig Arakawa at
202-551-3650 if you
have questions regarding these comments.



FirstName LastNameMichael Zechmeister                        Sincerely,
Comapany NameC. H. Robinson Worldwide, Inc.
                                                             Division of
Corporation Finance
December 14, 2020 Page 2                                     Office of Energy &
Transportation
FirstName LastName