SEC Comment Letter for American Airlines Group (AAL) — Jun 9, 2015
American Airlines Group Inc.
Date: June 9, 2015 · CIK: 0000006201 · Accession: 0000000000-15-030693
AI Filing Summary & Sentiment
File numbers found in text: 001-08400
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June 9, 2015
Mr. Derek J. Kerr
Chief Financial Officer
American Airlines Group, Inc.
4333 Amon Carter Boulevard
Fort Worth, Texas 76155
Re: American Airlines Group Inc.
Form 10-K for Fiscal Year Ended December 31, 2014
Filed February 25, 2015
File No. 001-08400
Dear Mr. Kerr:
We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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.
Management’s Discussion and Analysis of Financial Condition and Results of Operations
American Airlines Group , page 68
1. We note that you combine separate company results of AAG and US Airways for 2013
for purposes of discussion and analysis of your results of operations. We also note that
you discuss the combined separate company results of 2013 and 2012 on page 73. Please
be adv ised that it is not appropriate to merely combine the results for the AAG and US
Airways for purposes of MD&A discussion or otherwise as the financial statements have
not been prepared on a consistent basis and therefore are not comparable . In lieu of thi s
presentation, you may supplement your MD&A discussion of your historical results with
a discussion of your results prepared on a pro forma basis in a format consistent with the
rules prescribed under Article 11 of Regulation S -X. Please revise according ly.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require . Since the company and its management are
Mr. Derek J. Kerr
American Airlines Group, Inc.
June 9 , 2015
Page 2
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 connection with responding to our comments, please p rovide, in writing , a statement
from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
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 federal securities laws of the United States.
You may contact Effie Simpson at (202) 551-3346 , or in her absence, Jean Yu at (202)
551-3305 if you have questions regarding comments on the financial statements and related
matters. Please contact me at ( 202) 551 -3379 with any other questions.
Sincerely,
/s/ Melissa Raminpour
Melissa Raminpour
Branch Chief