SecProbe.io

September 10 , 2013

Via E -mail
David Barger
President and Chief Executive Officer
JetBlue Airways Corporation
27-01 Queens Plaza North
Long Island City, New York 11101

 Re: JetBlue Airways Corporation
  Form 10 -K for the Fiscal Year Ended December 31, 2012
  Filed February 21, 2013
  File No. 0 -49728

Dear Mr. Barger:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   At this juncture, we are asking you to provide us with information so we m ay
better understand your disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts an d circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

General

1. We note a blog post on your website dated 9/2/2011 indicating that you would begi n
charter services to Havana, Cuba.  An article published in April 2012 confirms that a
charter operator uses your planes for flights servicing Cuba.  Cuba is designated by the
Department of State as a state sponsor of terrorism and is subject to U.S. ec onomic
sanctions and export controls.  Please describe to us the nature and extent of your past,
current, and anticipated contacts with Cuba, whether through subsidiaries, affiliates or
other direct or indirect arrangements.  Your response should describe any services,
products or technology you have provided to or received from Cuba, directly or
indirectly, and any agreements, commercial arrangements, or other contacts you have had
with the Cuban government  or entities it controls.

David Barger
JetBlue Airways Corporation
September 10, 2013
Page 2

 2. Please discuss the mat eriality of any contacts with Cuba described in response to the
foregoing comment, and whether those contacts constitute a material investment risk for
your security holders.  You should address materiality in quantitative 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 investor would deem important in making an
investment decision, including the potential impact of corporate activities upon a
company’s reputation and share value.  Various state and municipal governments,
universities, and other investors have proposed or adopted divestment or similar
initiatives re garding investment in companies that do business with U.S. -designated state
sponsors of terrorism.  Your materiality analysis should address the potential impact of
the investor sentiment evidenced by such actions directed toward companies that have
operat ions associated with Cuba.

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rul es require.  Since the company and its management are
in possession of all facts relating to the company’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

David Barger
JetBlue Airways Corporation
September 10, 2013
Page 3

 Please contact Daniel Leslie, Staff Attorney, at (202) 551 -3876  or me at (202) 551 -3470
if you have any questions about the comments or our review.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Max Webb
  Assistant Director
 Division of Corporation Finance

 Donald Daniels
 Chief Financial Officer

 James Hnat
 General Counsel