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SEC Comment Letter for American Airlines Group (AAL) — Apr 13, 2017

American Airlines Group Inc.
Date: April 13, 2017 · CIK: 0000006201 · Accession: 0000000000-17-012821

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

File numbers found in text: 001-08400

Referenced dates: April 3, 2017, March 22, 2017

Date
December 31, 2016
Author
/s/ Melissa Raminpour
Form
UPLOAD
Company
American Airlines Group Inc.

Letter

Mail Stop 3561 April 13 , 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 reviewed your response letter dated April 3, 2017, 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. Unless we note otherwise, our references to prior comments are to comments in our March 22, 2017 letter.

General

1. In your response to comment 1 in our letter dated March 22, 2017, you state that U.S. air carriers are not prohibited from selling tickets for travel to or from Syria or Sudan on flight s operated by other carriers. However, you do not specify whether you engage, or have engaged, in such activity. Please clarify for us whether you sell tickets for travel to Syria and/or Sudan, and whether you have done so since your letter to us dated J une 3, 2013. As we noted in comment 1, your website lists flights to Khartoum, Sudan.

2. You state in your responses to comments 1 and 2 in our letter dated March 22, 2017, that your contacts with Syria or Sudan “if any” are limited. Please clarify for u s whether you have had direct or indirect contacts with Syria and/or Sudan since your letter to us dated June 3, 2013, and describe to us all such contacts.

Mr. Derek J. Kerr American Airlines Group, Inc. April 13 , 2017 Page 2

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

Sincerely,
/s/ Melissa Raminpour

Show Raw Text
Mail Stop 3561
        April 13 , 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 reviewed your response letter dated April 3, 2017, 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.   Unless we note otherwise, our references to prior comments are to comments in our
March 22, 2017 letter.

General

1. In your response to comment 1 in our letter dated March 22, 2017, you state that U.S. air
carriers are not prohibited from selling tickets for travel to or from Syria or Sudan on
flight s operated by other carriers.  However, you do not specify whether you engage, or
have engaged, in such activity.  Please clarify for us whether you sell tickets for travel to
Syria and/or Sudan, and whether you have done so since your letter to us dated J une 3,
2013.  As we noted in comment 1, your website lists flights to Khartoum, Sudan.

2. You state in your responses to comments 1 and 2 in our letter dated March 22, 2017, that
your contacts with Syria or Sudan “if any” are limited.  Please clarify for u s whether you
have had direct or indirect contacts with Syria and/or Sudan since your letter to us dated
June 3, 2013, and describe to us all such contacts.

Mr. Derek J. Kerr
American Airlines Group, Inc.
April 13 , 2017
Page 2

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

Sincerely,

               /s/ Melissa Raminpour

Melissa  Raminpour
Branch Chief
Office of Transportation and Leisure