SecProbe.io

October 18, 2011
 Ms. Isabella D. Goren  Chief Financial Officer AMR Corporation 4333 Amon Carter Blvd. Fort Worth, Texas 76155
Re: AMR Corporation
 Form 10-K for the Year Ended December 31, 2010
Filed February 16, 2011 Form 10-Q for the Quarterly Period Ended June 30, 2011 Filed July 20, 2011 File No. 001-08400         American Airlines, Inc.
 Form 10-K for the Year Ended December 31, 2010
Filed February 16, 2011 File No. 001-02691

Dear Ms. Goren:
 We have reviewed your filings 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 this letter within te n business days by amending your filings, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your f ilings and the information you provide in
response to these comments, we ma y have additional comments.
            AMR Corporation Form 10-Q for the Quarterly Period Ended June 30, 2011

 Item 2. Management’s Discussion and Analysis

 Significant Indebtedness and Future Financing, page 19

1. We note your recent decisions to close a crew base in San Francisco, cut seating capacity
and ground more than 10 jets.  We also note th at almost all of your aircraft assets are

Ms. Isabella D. Goren AMR Corporation and American Airlines, Inc. October 18, 2011 Page 2

 encumbered, that certain of your debt financ ing agreements contain loan-to-value ratio
covenants and that you are require d to periodically a ppraise the collateral (aircraft) to
assess compliance with these covenants.  Y ou disclose, on page 20, the fact that “the
market value of these aircraft assets has decl ined in recent years, and may continue to
decline.”  Given these events  and circumstances, please tell us about the impairment
analysis that you conducted in the third quarter , as disclosed in Footnote 11.  Describe,
supplementally and in detail, the significant estimates and assumptions utilized in your
analysis and the conclusions that you reach ed.  Explain how you determined the assets
considered to be held for use and, to the exte nt applicable, the asse ts considered to be
held for sale and/or to be disposed of other than by sale.  We may have further comments
upon review of your response.

2. To facilitate our understanding of your debt fi nancing arrangements, please tell us more
about each individually significant financing ag reement that includes a loan-to-value ratio
covenant.  Describe the nature of loan-to-va lue requirement, identify the specific aircraft
to which it applies, and numerically illustr ate your degree of compliance with the ratio
requirement as of the most recent balance sheet date.

3. As a related matter, if you are subject to any form of residual value guarantees in
connection with your leased aircraft, please provide comparable information regarding
the nature and amount of each such guarant ee and an illustration of your degree of
compliance with same.
 American Airlines, Inc. Form 10- K for the Year Ended December 31, 2010

 Liquidity and Capital Resources

Off Balance Sheet Arrangements, page 31
4. Please tell us why you have not included a Table of Contractual Obligations in
accordance with Item 303(A)(5 ) of Regulation S-K.  Include in your response why you
have included a cross-reference to “Contractual Obligations” on page 29.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

Ms. Isabella D. Goren AMR Corporation and American Airlines, Inc. October 18, 2011 Page 3

  staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Amy Geddes at 202-551-3304 or Margery Reich at 202-551-3347 if
you have questions regarding comments on the fina ncial statements and related matters.  Please
contact me at 202-551-3211 w ith any other questions.

Sincerely,
   /s/ David R. Humphrey
David R. Humphrey Accounting Branch Chief