October 9, 2019 Robert M. Knight, Jr. Chief Financial Officer Union Pacific Corporation 1400 Douglas Street Omaha, Nebraska 68179 Re: Union Pacific Corporation Form 10-K for the Fiscal Year Ended December 31, 2018 Filed February 8, 2019 File No. 001-06075 Dear Mr. Knight, Jr.: 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