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SEC Company Response from INTERNATIONAL LEASE FINANCE CORP (CIK 0000714311) — Dec 22, 2004

INTERNATIONAL LEASE FINANCE CORP (CIK 0000714311)
Date: Dec. 22, 2004 · CIK: 0000714311 · Accession: 0000902595-04-000059

AI Filing Summary & Sentiment

File numbers found in text: 333-120649

Referenced dates: November 30, 2004

Date
December 22, 2004
Author
Vice Chairman and Chief Financial Officer
Form
CORRESP
Company
INTERNATIONAL LEASE FINANCE CORP (CIK 0000714311)

Letter

Re: International Lease Finance Corporation Registration Statement on Form S-3 File No. 333-120649

[INTERNATIONAL LEASE FINANCE CORPORATION LETTERHEAD]

December 22, 2004

Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549

Ladies and Gentlemen:

In response to the comments contained in the Staff's letter, dated November 30, 2004, regarding the above-referenced Registration Statement (the "Registration Statement"), on December 10, 2004, International Lease Finance Corporation (the "Company") filed a Form 10-Q/A for the quarter ended September 30, 2004 with the additional disclosure previously discussed with the Staff.

We hereby request that the Registration Statement be accelerated to 8:00 a.m., Eastern Standard Time, on December 28, 2004 or as soon thereafter as practicable.

We acknowledge in making this request that:

* should the Securities and Exchange Commission (the "Commission") or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

* the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

* the Company may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
/s/ Alan H. Lund
Alan H. Lund
Vice Chairman and Chief Financial Officer

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
             [INTERNATIONAL LEASE FINANCE CORPORATION LETTERHEAD]

December 22, 2004

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

          Re:  International Lease Finance Corporation
               Registration Statement on Form S-3
               File No. 333-120649

Ladies and Gentlemen:

            In response to the comments contained in the Staff's letter, dated
November 30, 2004, regarding the above-referenced Registration Statement (the
"Registration Statement"), on December 10, 2004, International Lease Finance
Corporation (the "Company") filed a Form 10-Q/A for the quarter ended September
30, 2004 with the additional disclosure previously discussed with the Staff.

            We hereby request that the Registration Statement be accelerated to
8:00 a.m., Eastern Standard Time, on December 28, 2004 or as soon thereafter as
practicable.

            We acknowledge in making this request that:

               *    should the Securities and Exchange Commission (the
                    "Commission") or the Staff, acting pursuant to delegated
                    authority, declare the Registration Statement effective, it
                    does not foreclose the Commission from taking any action
                    with respect to the Registration Statement;

               *    the action of the Commission or the Staff, acting pursuant
                    to delegated authority, in declaring the Registration
                    Statement effective, does not relieve the Company from its
                    full responsibility for the adequacy and accuracy of the
                    disclosure in the Registration Statement; and

               *    the Company may not assert this action as a defense in any
                    proceeding initiated by the Commission or any person under
                    the federal securities laws of the United States.

                                  Very truly yours,

                                  /s/ Alan H. Lund
                                  Alan H. Lund
                                  Vice Chairman and Chief Financial Officer

</TEXT>
</DOCUMENT>