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ELLIS FUNK, P.C.

  Robert
  N. Dokson

  Attorneys At Law

  Of
  Counsel:

  Neal
  J. Fink

  One Securities Centre

  Donald
  J. Ellis (GA & VA)

  Robert
  B. Goldberg (GA & SC)

  Suite 400

  David
  I. Funk

  Amy
  L. Kaye

  3490 Piedmont Road, N.E.

  Russell
  H. Kasper, P.C.

  Albert
  L. Labovitz (GA & AL)

  Atlanta, Georgia 30305-1743

  Jane
  R. Leitz

  M.
  Barry Leitz

  404-233-2800

  Clay
  M. White

  Facsimile 404-233-2188

  E-mail:
  rgoldberg@ellisfunk.com

December 8, 2009

Ms. Theresa Messinese

Division of Corporation
Finance

United States Securities and
Exchange Commission

100 F Street NE

Washington, D.C 20549

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

File No. 000-31683

Dear Ms. Messinese:

This letter is in response
to the Staff’s comment letter issued on October 14, 2009, with respect to
the above-referenced matter concerning Allegiant Travel Company (the “Company”).
The following responds to the item numbers in the Staff’s comment letter:

Selected Financial Data page 29:

1.                                      Your
response to prior comment 2 is unclear with regard to the presentation of
ancillary revenue per ASM. Please tell us the meaningfulness of providing
available seat miles in relation to ancillary 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.

Company Response:

All
airlines report revenues on a per ASM basis as ASM’s are the commonly used unit
of production in the airline industry.
All airlines have revenue sources which are not directly related to ASM
production.  These sources of revenue
include ancillary revenue (baggage fees and seat assignment fees are now
commonplace in the industry), cargo or package delivery revenues, mail
revenues, revenues from sponsored credit card programs, etc.  To enable investors to compare the Company’s
results on a per ASM basis with the results of other airlines and to be
consistent with the principle espoused in Staff comment #3 (addressed below),
we believe the Company should continue to disclose its revenue production on a
per ASM basis.  However, in response to
Staff’s comment, in future filings, the Company will provide footnote
disclosure indicating those revenue per ASM line items where there may not be a
direct correlation between the revenues generated and ASM production.

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 attributable to third-party products and unbundled air
travel related charges is an arbitrary grouping, as you state in your 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-categories would
not be meaningful to investors. To the contrary, given the rapidly growing
significance of these amounts to your reported results, it appears 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 discuss
revenues from these two ancillary revenue sub-categories.

Company Response:

The
Company has further considered the Staff’s comment concerning separate
disclosure of ancillary revenues attributable to third-party products and
unbundled travel-related charges.  The
Company agrees in future filings to separately disclose these two
sub-categories of ancillary revenues and to discuss, where material, changes in
the sub-categories from period to period.

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 operations and scheduled service operations.
While we agree that readers could in fact perform these calculations and
attempt to draw their own conclusions from the resulting 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 management. In addition, we believe
that providing a direct analysis of fixed fee contract revenue will provide a
more user friendly presentation of your results to your investors.
Therefore, we reissue our prior comment and request that you revise your
discussion and analysis to disclose information that will provide context for
the results of your fixed fee contract business.

Company Response:

In
response to the Staff’s comment and in an attempt to provide more user friendly
discussion and analysis of the Company’s fixed fee contract revenues, the
Company will in future filings provide disclosure, where material, as to how
changes in block hours flown, fixed fee departures or other relevant metrics
impact fixed fee contract revenues.

2

Please confirm that the
foregoing satisfies the concerns expressed in the Staff’s comment letter. Please
contact me at (404) 233-2800 should you require additional information or have
questions regarding this letter.

  Sincerely,

  /s/ Robert B. Goldberg

  Robert B. Goldberg

  RBG:jll

  cc:  Maurice J. Gallagher, Jr.

        Andrew
  C. Levy

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