[SONNENSCHEIN NATH & ROSENTHAL LLP LETTERHEAD]


Marc Salle
816.460.2555
msalle@sonnenschein.com


VIA EDGAR AND FEDERAL EXPRESS

December 19, 2007

Daniel Morris, Esq.
Attorney - Advisor
Mail Stop 3561
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

RE:  Comment Letter dated December 10, 2007 Issued to Kansas City Southern
     Definitive 14A
     Filed March 30, 2007
     File No. 001-04717

Dear Mr. Morris:

     We serve as counsel to Kansas City Southern ("KCS") and are in receipt of a
copy of your comment  letter dated December 10, 2007 addressed to Mr. Michael R.
Haverty,  Chief  Executive  Officer of KCS, with regard to the  above-referenced
proxy statement.

     We note that the letter  requests a response by December 21, 2007. In order
to  give it time  to  discuss  its  proposed  responses  with  the  compensation
committee,  KCS  respectfully  requests an extension  until January 11, 2008, in
which to respond to your comments.

     If you will recall,  we spoke by telephone  yesterday  with regard to KCS's
extension request. You were kind enough to grant that request,  conditioned upon
filing of this letter.

     We appreciate your assistance and the comments raised in your letter.

     Thank you very much.

                                                   Best regards,

                                                   /s/ Marc Salle

                                                   Marc Salle

cc:  Brian P. Banks, Esq.
     John F. Marvin, Esq.