SEC Comment Letter for AIR LEASE CORP (AL) (CIK 0001487712) (AL) — Apr 25, 2012

AIR LEASE CORP (AL) (CIK 0001487712)
Date: April 25, 2012 · CIK: 0001487712 · Accession: 0000000000-12-021255

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

April 25, 2012

Author

/s/ W. John Cash W. John Cash B r a n c h C h i e f

Form

UPLOAD

Company

AIR LEASE CORP (AL) (CIK 0001487712)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE April 25, 2012 Via Facsimile Mr. Gregory B. Willis Chief Financial Officer Air Lease Corporation 2000 Avenue of the Stars, Suite 1000N Los Angeles, CA 90067

Re: Air Lease Corporation Form 10-K for the Fiscal Year Ended December 31, 2011 Filed March 9, 2012 File No. 1-35121

Dear Mr. Willis: We have completed our review of your f iling. We remind you that our comments or changes to disclosure in res ponse to our comments do not for eclose the Commission from taking any action with respect to the company or th e filing and the company may not assert staff comments as a defense in any proceeding ini tiated by the Commission or any person under the federal securities laws of the United States. We urge all pers ons who are responsible for the accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ W. John Cash W. John Cash B r a n c h C h i e f

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

DIVISION OF
CORPORATION FINANCE
         April 25, 2012
 Via Facsimile

Mr. Gregory B. Willis Chief Financial Officer Air Lease Corporation 2000 Avenue of the Stars, Suite 1000N Los Angeles, CA  90067

 Re: Air Lease Corporation
  Form 10-K for the Fiscal Year Ended December 31, 2011
Filed March 9, 2012
  File No.  1-35121

 Dear Mr. Willis:
We have completed our review of your f iling.  We remind you that our comments or
changes to disclosure in res ponse to our comments do not for eclose the Commission from taking
any action with respect to the company or th e filing and the company may not assert staff
comments as a defense in any proceeding ini tiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pers ons who are responsible for the
accuracy and adequacy of the disclosure in the fi ling to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
         /s/ W. John Cash          W. John Cash         B r a n c h  C h i e f

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