SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

         November 23, 2009           Mr. Andrew C. Levy Chief Financial Officer  Allegiant Travel Company 8360 S. Durango Drive Las Vegas, NV  89113   Re: Allegiant Travel Company
Form 10-K for the fiscal year ended December 31, 2008
  File No. 000-31683

Dear Mr. Levy:
  We have reviewed your correspondence dated November 10, 2009 and have the
following comments.  Unless otherwise indica ted, we believe you should revise future
filings in response to these comments.  If you disagree, we will consid er your explanation
as to why a revision is unnecessary.  Pleas e be as detailed as necessary in your
explanation.  Additionally, we ask you to provi de us with further information so we may
better understand your disclosure.  After re viewing this information, we may raise
additional comments.     Please file your response to our comment s via EDGAR, under the label “corresp,”
within ten business days from the date of this letter.

Form 10-K for the fiscal year ended December 31, 2008

Selected Financial Data, page 29

1. Your response to prior comment 2 is uncle ar with regard to the presentation of
ancillary revenue per ASM.  Please tell us the meaningfulness of providing
available seat miles in relation to anci llary revenue (for example, how does it
impact revenue derived by hotel rooms)  or eliminate revenues not driven by
changes in the number of available seat  miles from the various metrics.
 Item 7.  Results of Operations, page 35

2. We note your response to prior comment 4.  We are unclear as to why the
separate presentation of revenues attr ibutable to third-party products and
unbundled air travel related charges is an  arbitrary grouping, as you state in your

Allegiant Travel Company
November 23, 2009 Page 2 of 2
response, especially considering the fact that they were grouped this way for your
investors in your investor presentation.  While ancillary revenue may be impacted
by multiple factors, not all of which are under your control, we do not agree that
this means quantifying and discussing revenues from the third-party products and unbundled travel-related charges sub-categ ories would not be meaningful to
investors.  To the contrary, given th e rapidly growing significance of these
amounts to your reported results, it appear s that a more detailed disclosure would
provide very useful insight into your results to your investors, whether you can
attribute all variances to known factors or not.  Therefore, we believe you should
revise to separately quantify and disc uss revenues from these two ancillary
revenue sub-categories.

3. We note your response to prior comment 6 in which you state that readers can
analyze your fixed fee contract revenue by examining the differences between the
statistics provided for total system oper ations and scheduled service operations.
While we agree that readers could in fact  perform these calculations and attempt
to draw their own conclusions from the re sulting data, we believe that the intent
of MD&A disclosure is to provide a discussion and analysis of results of
operations through the eyes of manageme nt.  In addition, we believe that
providing a direct analysis of fixed fee c ontract revenue will provide a more user
friendly presentation of your results to your investors.  Therefore, we reissue our
prior comment and request that you revi se your discussion and analysis to
disclose information that will provide c ontext for the results of your fixed fee
contract business.

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   Please contact Theresa Messinese at 202-551-3307 or the undersigned at 202-551-
3380 with any questions.
Sincerely,

Lyn Shenk Branch Chief
Cc:  Robert B. Goldberg, Counsel