<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo





                            January 18, 2022

       Adam Satterfield
       Chief Financial Officer
       Old Dominion Freight Line, Inc.
       500 Old Dominion Way
       Thomasville, NC 27360

                                                        Re: Old Dominion
Freight Line, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 24,
2021
                                                            File No. 000-19582

       Dear Mr. Satterfield:

              We have reviewed your November 5, 2021 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
       October 15, 2021 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Risk Factors, page 6

   1.                                                   Your response to prior
comment 1 states that you comprehensively monitor the risks faced
                                                        by your business,
including transition risks related to climate change. Please
                                                        describe the process
through which you monitor risk and explain in greater detail how you
                                                        determined that
transition risks related to climate change are not individually material.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       20

   2.                                                   We note your response
to prior comment 2 regarding the significant physical effects of
                                                        climate change on your
operations and results. Consistent with comment 2 from our letter
                                                        dated September 14,
2021, provide us with quantitative information supporting the
 Adam Satterfield
Old Dominion Freight Line, Inc.
January 18, 2022
Page 2
         statement that you have not experienced material weather-related
damages to your
         property or operations. In addition, quantify and tell us about any
weather-related impacts
         on the cost or availability of insurance.
      You may contact Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the
comments.



FirstName LastNameAdam Satterfield                            Sincerely,
Comapany NameOld Dominion Freight Line, Inc.
                                                              Division of
Corporation Finance
January 18, 2022 Page 2                                       Office of Energy
& Transportation
FirstName LastName
</TEXT>
</DOCUMENT>
