SEC Company Response from DELTA AIR LINES, INC. (DAL) (CIK 0000027904) (DAL) — Mar 9, 2022
DELTA AIR LINES, INC. (DAL) (CIK 0000027904)
Date: March 9, 2022 · CIK: 0000027904 · Accession: 0001683168-22-001544
AI Filing Summary & Sentiment
File numbers found in text: 001-05424
Referenced dates: February 25, 2022
Letter
Division of Corporation Finance RE: DELTA AIR LINES, INC. Form 10-K for the Year Ended December 31, 2021 Filed February 11, 2022 File No. 001-05424
Dear Mr. Rodriguez and Mr. Babula:
This is in response to the Staff's letter dated February 25, 2022 regarding Delta's Annual Report on Form 10-K for the year ended December 31, 2021. For your convenience, we have included in this letter the Staff's comment before providing our response to that comment.
* * * * * * * *
Form 10-K for the Year Ended December 31,
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations, page 34
1. Please discuss and analyze revenue and passenger levels and their respective trends for business related travel and leisure and other travel. Please refer to Item 303 of Regulation S-K.
Response:
We appreciate the opportunity to discuss this comment with the Staff and appreciate the feedback from the Staff reflected in this comment. In response to the Staff’s comment, we respectfully advise the Staff that in preparing the management's discussion and analysis of financial condition and results of operations (“MD&A”) in our Form 10-K, we evaluated the requirements of Item 303 of Regulation S-K (including available guidance from the Staff) and considered the information we use to monitor and manage our business as well as the information disclosed in our other investor communications to the extent material. This is reflected in our discussion in Results of Operations of the trends we have seen in the recovery of our revenues in 2021 from the impact of the pandemic and our expectations for continuing recovery. While we believe the disclosures in our MD&A address the requirements of Item 303 of Regulation S-K and are consistent with our other investor communications, we acknowledge that additional detail related to business and leisure (or consumer) travel trends may be helpful to investors. As a result, to the extent material, we will evaluate including additional information in our discussion of Results of Operations in future filings about the recovery of business and consumer travel relative to the pre-COVID-19 period.
* * * * * * * *
We sincerely hope that we have thoroughly addressed your comment on our 2021 Form 10-K filed on February 11, 2022.
We will be pleased to respond promptly to any additional requests for information or material that we may provide in order to facilitate your review. If you have any questions, please contact me at 404-773-5558 or bill.carroll@delta.com.
Very Truly Yours,
/s/ William Carroll
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filename1.htm
William Carroll
Senior Vice President -
Controller
Delta Air Lines, Inc.
1030 Delta Boulevard
Atlanta, Georgia 30354
T: +1 404 773 5558
bill.carroll@delta.com
March 9, 2022
Mr. Gus Rodriguez
Mr. Robert Babula
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE:
DELTA AIR LINES, INC.
Form 10-K for the Year Ended December 31, 2021
Filed February 11, 2022
File No. 001-05424
Dear Mr. Rodriguez and Mr. Babula:
This is in response to the
Staff's letter dated February 25, 2022 regarding Delta's Annual Report on Form 10-K for the year ended December 31, 2021. For your convenience,
we have included in this letter the Staff's comment before providing our response to that comment.
* * * * * * * *
Form 10-K for the Year Ended December 31,
2021
Item 7. Management's Discussion and Analysis of Financial Condition
and Results of Operations, page 34
1. Please discuss and analyze revenue and passenger levels and their respective trends for business related travel and leisure and
other travel. Please refer to Item 303 of Regulation S-K.
Response:
We appreciate the opportunity to discuss this
comment with the Staff and appreciate the feedback from the Staff reflected in this comment. In response to the Staff’s comment,
we respectfully advise the Staff that in preparing the management's discussion and analysis of financial condition and results of operations
(“MD&A”) in our Form 10-K, we evaluated the requirements of Item 303 of Regulation S-K (including available guidance from
the Staff) and considered the information we use to monitor and manage our business as well as the information disclosed in our other
investor communications to the extent material. This is reflected in our discussion in Results of Operations of the trends we have seen
in the recovery of our revenues in 2021 from the impact of the pandemic and our expectations for continuing recovery. While we believe
the disclosures in our MD&A address the requirements of Item 303 of Regulation S-K and are consistent with our other investor communications,
we acknowledge that additional detail related to business and leisure (or consumer) travel trends may be helpful to investors. As a result,
to the extent material, we will evaluate including additional information in our discussion of Results of Operations in future filings
about the recovery of business and consumer travel relative to the pre-COVID-19 period.
* * * * * * * *
We sincerely hope that we
have thoroughly addressed your comment on our 2021 Form 10-K filed on February 11, 2022.
We will be pleased to respond
promptly to any additional requests for information or material that we may provide in order to facilitate your review. If you have any
questions, please contact me at 404-773-5558 or bill.carroll@delta.com.
Very Truly Yours,
/s/ William Carroll
Senior Vice President -
Controller
cc:
Dan Janki, Executive Vice President – Chief Financial Officer
Peter Carter, Executive Vice President – Chief Legal Officer