SEC Comment Letter for AIR LEASE CORP (AL) (CIK 0001487712) (AL) — Mar 21, 2011
AIR LEASE CORP (AL) (CIK 0001487712)
Date: March 21, 2011 · CIK: 0001487712 · Accession: 0000000000-11-017304
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-171734
Referenced dates: March 7, 2011
Letter
March 21, 2011 John L. Plueger President & Chief Operating Officer Air Lease Corporation 2000 Avenue of the Stars, Suite 600N Los Angeles, CA 90067 Re: Air Lease Corporation Amendment No. 4 to Registrati on Statement on Form S-1 Filed March 11, 2011 File No. 333-171734
Dear Mr. Plueger:
We have reviewed your amended registra tion statement and response letter filed March 11, 2011 and have the following comment. After reviewing any amendment to your re gistration statement and the information you provide in response to the comment, we may have additional comments. General
1. We note your response to prior comment thr ee in our letter dated March 7, 2011. Please tell us whether or not to the best of your knowledge, understanding and belief your aircraft are used or will be used on routes to Iran, Syria and/or Sudan by Air Arabia and Etihad Airways. You may contact Kevin Stertzel at (202) 551-3723 or, in hi s absence, Anne McConnell, at (202) 551-3709 if you have ques tions regarding financial statem ents and related matters. You may contact Jennifer Hardy at (202) 551-3767 if you have questi ons regarding the comment on contacts with Iran, Syria and Sudan. Please contact Chambre Malone at (202) 551-3262 or, in her absence, me at (202) 551-3765 with any other questions. Sincerely,
Pamela Long Assistant Director
Mr. John L. Plueger Air Lease Corporation March 21, 2011 Page 2
cc: Robert B. Knauss, Esq. ( via facsimile at (213) 683-5137) Munger, Tolles & Olson LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071
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March 21, 2011 John L. Plueger President & Chief Operating Officer Air Lease Corporation 2000 Avenue of the Stars, Suite 600N Los Angeles, CA 90067 Re: Air Lease Corporation Amendment No. 4 to Registrati on Statement on Form S-1 Filed March 11, 2011 File No. 333-171734 Dear Mr. Plueger: We have reviewed your amended registra tion statement and response letter filed March 11, 2011 and have the following comment. After reviewing any amendment to your re gistration statement and the information you provide in response to the comment, we may have additional comments. General 1. We note your response to prior comment thr ee in our letter dated March 7, 2011. Please tell us whether or not to the best of your knowledge, understanding and belief your aircraft are used or will be used on routes to Iran, Syria and/or Sudan by Air Arabia and Etihad Airways. You may contact Kevin Stertzel at (202) 551-3723 or, in hi s absence, Anne McConnell, at (202) 551-3709 if you have ques tions regarding financial statem ents and related matters. You may contact Jennifer Hardy at (202) 551-3767 if you have questi ons regarding the comment on contacts with Iran, Syria and Sudan. Please contact Chambre Malone at (202) 551-3262 or, in her absence, me at (202) 551-3765 with any other questions. Sincerely, Pamela Long Assistant Director Mr. John L. Plueger Air Lease Corporation March 21, 2011 Page 2 cc: Robert B. Knauss, Esq. ( via facsimile at (213) 683-5137) Munger, Tolles & Olson LLP 355 South Grand Avenue, 35th Floor Los Angeles, CA 90071