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                                                            July 25, 2024

Brian O. Newman
Chief Financial Officer
United Parcel Service, Inc.
55 Glenlake Parkway, NE
Atlanta, GA 30328

        Re: United Parcel Service, Inc.
            Form 10-K for the Fiscal Year ended December 31, 2023
            Filed February 20, 2024
            File No. 001-15451
Dear Brian O. Newman:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2023
Management's Discussion and Analysis, page 23

1.      We note that you present various non-GAAP measures on pages 24 through
42, although
        differentiation from similar GAAP measures is limited to using the term
adjusted in the
        label (e.g. adjusted diluted earnings per share; segment measures of
adjusted operating
        expenses, adjusted operating profit, and adjusted operating margin; and
consolidated
        measures of adjusted compensation and benefit, adjusted total other
expense, adjusted
        total operating expenses, adjusted investment income and other,
adjusted other income
        and (expense), adjusted income tax expense, and adjusted effective tax
rate).

        We believe that disclosures made in presenting non-GAAP measures should
more clearly
        convey their nature as non-GAAP measures, than is provided by the term
adjusted in
        isolation of the term non-GAAP, either within the label, as a header to
sections within
        tabulations that include such measures, or in close proximity to an
associated
        discussion and analysis. Please modify your disclosures as necessary to
clearly identify
 July 25, 2024
Page 2

       any adjusted measures that are not compiled in accordance with GAAP, as
non-GAAP
       measures, consistent with the guidance in Item 10(e)(1)(ii)(E) of
Regulation S-K and the
       Answer to Question 100.05 of our Compliance & Disclosure Interpretations
for Non-
       GAAP Measures. You may view this guidance at the following website
address:
       https://www.sec.gov/corpfin/non-gaap-financial-measures.htm

2.     We note that in presenting various non-GAAP measures you have made
adjustments to
       eliminate the effects associated with costs that you have reported as
transformation
       strategy costs, which you characterize as compensation and benefits, or
something other
       than compensation and benefits, on page 131 of your financial
statements. However, you
       have not described your initiatives and strategies sufficiently to
understand why these
       would be excluded in compiling your non-GAAP measures.

       Given that you first associated this category of costs with a
"multi-year enterprise-wide
       transformation strategy" in 2018, and have continued to report such
costs for six
       years with no update on the plan, other than to identify an incremental
initiative involving
       workforce reduction at the end of 2023, it is unclear how these costs
would not constitute
       normal, recurring, cash operating expenses that are necessary to operate
the business.

       Please expand your disclosures to provide information about the
transformation strategies
       undertaken each year, including the associated costs, any qualitative
results, and the status
       of the plans. Please address the guidance specific to MD&A that we have
provided in
       SAB Topic 5:P.4, to the extent directly applicable for restructuring,
disposal and exit
       activities, or by analogy where this would yield meaningful disclosure.

       Tell us why you believe the transformation strategy costs are
appropriately excluded in
       calculating the non-GAAP measures that you present, considering the
extended period
       over which such costs are recurring, and explain why you believe the
adjustments would
       not be contrary to the guidance in the Answer to Question 100.01 of our
Compliance and
       Disclosure Interpretations for Non-GAAP Measures, if this is your view.

       In conjunction with the foregoing, provide us with a schedule listing
the particular facets
       of each phase of the plan that were implemented each year since the plan
was introduced,
       including the associated costs, and describe the scope and duration of
each phase.
       Please identify the specific changes that were made to processes and
technologies, and
       explain how you have assessed any resulting modernization, quality
enhancement, and
       efficiency, which were initially set forth as objectives of the plan.

3.     We note that you have included various non-GAAP measures along with the
earnings
       releases filed on Form 8-K on January 30, 2024 and April 23, 2024, under
the heading
          Reconciliation of GAAP and Non-GAAP Income Statement Items
presented in Exhibit
       99.1 and the    Reconciliation of GAAP and As Adjusted Income Statement
Data
       presented in Exhibit 99.2 of those current reports.

       However, reconciliations provided under those headings each identify an
entire column of
       activity as non-GAAP measures, even though some of the components appear
to be
 July 25, 2024
Page 3

       unadjusted GAAP measures. We see that you have excluded revenues from
these
       tabulations though have included many line items that generally appear
on an income
       statement, such as operating expenses, operating profit, other income
and expenses,
       income tax expense, and income before and after taxes.

       Please modify your disclosures as necessary to more clearly identify and
differentiate
       non-GAAP measures from GAAP measures and to adhere to the guidance in
the Answer
       to Question 102.10(c) of our Compliance and Disclosure Interpretations
for Non-GAAP
       Measures, i.e. to avoid giving undue prominence to non-GAAP measures by
using an
       income statement format when presenting non-GAAP measures.

Financial Statements
Note 18 - Transformation Strategy Costs, page 131

4.     We note your disclosure explaining that you are undertaking an
enterprise-wide
       transformation that includes various initiatives that will involve
changes to processes and
       technology, and will impact your global direct and indirect operating
costs. You
       identify a workforce reduction initiative that resulted in a $205
million expense accrual in
       2023, though do not address any other activities associated with costs
of $435 million for
       2023, $178 million for 2022, and $380 million for 2021.

       We see that you have been reporting transformation strategy costs for
six years and had
       attributed those costs to a plan that was adopted in 2018, until 2022
when that reference
       was removed from your disclosure. We note that you have reported $1.956
billion in
       transformation strategy costs since the introduction of your plan.

       Please revise your disclosure to include further details about your
transformation strategy
       initiatives, to include clarifying the extent to which you regard the
associated activities as
       restructuring, exit or disposal activities subject to the disclosure
requirements in FASB
       ASC 420-10-50-1, which you may consider either directly applicable or by
analogy in
       formulating meaningful disclosures about your transformation strategies.

       For example, this may entail descriptions of the associated activities,
the facts and
       circumstances leading to the expected activities, expected completion
dates, and for the
       various relevant activities, the total amounts expected to be incurred,
amounts incurred
       during the period, and cumulative amounts incurred to date.
 July 25, 2024
Page 4

       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.

       Please contact Yong Kim at 202-551-3323 or Karl Hiller at 202-551-3686
with any
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Energy &
Transportation
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