SecProbe.io

May 14, 2018
Scott Sheldon
Chief Financial Officer
Allegiant Travel Company
1201 North Town Center Drive
Las Vegas, Nevada 89144
Re:Allegiant Travel Company
Form 10-K for Fiscal Year Ended December 31, 2017
Filed March 1, 2018
File No. 001-33166
Dear Mr. Sheldon:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2017
Item 9A. Controls and Procedures
Evaluation of disclosure controls and procedures., page 67
1.Your conclusion refers only to a portion of disclosure controls and procedures defined by
Exchange Act Rules 13a-15(e) and 15d-15(e). In this regard, it appears your conclusion
applies only to the portion referred to. Please confirm to us and revise to clarify, if true,
that your conclusion is in regard to the entirety of disclosure controls and procedures as
defined.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.

 FirstName LastNameScott Sheldon
 Comapany NameAllegiant Travel Company
 May 14, 2018 Page 2
 FirstName LastName
Scott Sheldon
Allegiant Travel Company
May 14, 2018
Page 2
            You may contact Abe Friedman at 202-551-8298 or Lyn Shenk at 202-551-3380 with
any questions.
Division of Corporation Finance
Office of Transportation and Leisure