United States securities and exchange commission logo December 14, 2020 William Harvey Chief Financial Officer Kirby Corporation 55 Waugh Drive, Suite 1000 Houston, TX 77007 Re: Kirby Corporation Form 10-K for the Year Ended December 31, 2019 Filed February 24, 2020 File No. 001-07615 Dear Mr. Harvey: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Energy & Transportation