SecProbe.io

Mail Stop 3561
        March 22, 2017

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 Fis cal Year Ended December 31, 2016
Filed February 22 , 2017
Form 8 -K furnished on January 27, 2017
 File No.  001-08400

Dear  Mr. Kerr:

We have limited our review of  your filing s to the financial statements and related
disclosures 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 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.

Form 10 -K for Fiscal Year  Ended December 31, 2016

General

1. In your letter to us dated June 3, 2013 , you described c ontacts with Syria and Sudan  and
we note y our website lists flights to Khartoum, Sudan.  The oneworld alliance website
lists flights to Sudan by partner airl ines and your oneworld alliance partner , Royal
Jordanian’s ,website includes two cities in Syria on its list of destinations.  As you are
aware, Syria and Sudan are designated by the State Department as state sponsors of
terrorism and are subject to U.S. economi c sanctions and export controls.  Please describe
to us the nature and extent of past, current, and anticipated contacts with Syria and Sudan
since your prior letter, whether through subsidiaries, affiliates, onealliance member
partners, or other direct or  indirect arrangements .  You should describe any products or
services, you have provided to Syria and Sudan, directly or indirectly, and any
agreements, commercial arrangements, or other contacts with the governments of those

Mr. Derek J. Kerr
American Airlines Group, Inc.
March 22, 2017
Page 2

 countries or entities they con trol.

2. Please discuss the materiality of any contacts with Syria and Sudan you describe in
response to  the comment above, and whether those contacts constitute a material
investment risk for your security holders.  You should address materiality in quantit ative
terms, including the approximate dollar amounts of any associated revenues, assets, and
liabilities for the last three fiscal years and the subsequent interim period .  Also, address
materiality in terms of qualitative factors that a reasonable invest or would deem
important in making an investment decision, including the potential impact of corporate
activities upon a company’s reputation and share value.  As you know, various state and
municipal governments, universities, and other investors have prop osed or adopted
divestment or similar initiatives regarding investment in companies that do business with
U.S.-designated state sponsors of terrorism.  You should address the potential impact of
the investor sentiment evidenced by such actions directed tow ard companies that have
operations associated with Syria and Sudan.

Item 6.  Selected Consolidated Financial Data

Reconciliation of GAAP to Non -GAAP Financial Measures, page 47

3. Please revise your disclosure of usefulness of non -GAAP measures, other than  mainline
and regional CASM, to investors to (a) eliminate descriptive language suggesting non -
GAAP financial measures are “more indicative” of your performance  and “more
comparable” to measures reported by other major airlines and (b) ensure that the
disclosure addresses each non -GAAP measure and explains why each measure is useful
to investors and management in terms that are substantive and specific to you. Refer to
Item 10(e)(1)(i)(C) to (D) of S -K and footnote 44 to FR -65.  Our comment also applies to
disclosures in your earnings released furnished in Form 8 -K on January 27, 2017.  In
your response, please provide us with proposed revisions to your current disclosures.

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.

You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned, at
(202) 551 -3750  if you have questions regarding com ments on the financial statements and
related matters.

Sincerely,

               /s/ Melissa Raminpour

Melissa  Raminpour
Branch Chief
Office of Transportation and Leisure