SEC Comment Letter for WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164) (WLFC) — Jun 25, 2008

WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164)
Date: June 25, 2008 · CIK: 0001018164 · Accession: 0000000000-08-031434

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Date

June 25, 2008

Author

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Company

WILLIS LEASE FINANCE CORP (WLFC) (CIK 0001018164)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE VIA FACSIMILE AND U.S. MAIL June 25, 2008 Bradley S. Forsyth Senior Vice President and Chief Financial Officer Willis Lease Finance Corporation 773 San Marin Drive, Suite 2215 Novato, California 91998 RE: Willis Lease Finance Corporation Form 10-K for Fiscal Year Ended December 31, 2007 Form 10-Q for Fiscal Quarter Ended March 31, 2008 File No. 1-15369

Dear Mr. Forsyth:

We have completed our review of your Fo rm 10-K and related filings and have no further comments at this time. If you have any further questions regard ing our review of your filings, please direct them to Ernest Greene, Staff Account ant, at (202) 551-3733, or in his absence, Nudrat Salik, Staff Acco untant, at (202) 551-3692.

S i n c e r e l y , R u f u s D e c k e r A c c o u n t i n g B r a n c h C h i e f

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                      June 25, 2008
Bradley S. Forsyth
Senior Vice President and Chief Financial Officer Willis Lease Finance Corporation 773 San Marin Drive, Suite 2215 Novato, California 91998
 RE: Willis Lease Finance Corporation
Form 10-K for Fiscal Year  Ended December 31, 2007
Form 10-Q for Fiscal Quarter Ended March 31, 2008 File No. 1-15369

Dear Mr. Forsyth:

We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time.
If you have any further questions regard ing our review of your filings, please
direct them to Ernest Greene, Staff Account ant, at (202) 551-3733, or in his absence,
Nudrat Salik, Staff Acco untant, at (202) 551-3692.

       S i n c e r e l y ,           R u f u s  D e c k e r         A c c o u n t i n g  B r a n c h  C h i e f

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