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CORRESP
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corresp

September 2, 2011

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attn:

     Jay Ingram

Hagen Ganem

    Re:

    Air Lease Corporation

Registration Statement on Form S-1 (File No. 333-173817)

    Acceleration Request

          Requested
Date: September 2, 2011

          Requested Time: 5:00 P.M. Eastern Time

Ladies and Gentlemen:

     Pursuant to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended,
Air Lease Corporation (the “Company”) hereby respectfully requests that the
above-referenced registration statement on Form S-1 (the “Registration Statement”) be
declared effective at the “Requested Date” and “Requested Time” set forth above, or
as soon thereafter as practicable, or at such later time as the Company or its counsel may orally
request via telephone call to the staff (the “Staff”) of the Division of Corporation
Finance of the U.S. Securities and Exchange Commission (the “Commission”).

     The Company hereby authorizes each of Robert B. Knauss, Mark H. Kim and Katherine Ku of
Munger, Tolles & Olson LLP, counsel to the Company, to make such request on our behalf.

U.S. Securities and Exchange Commission

September 2, 2011

Page 2 of 3

     In connection with this acceleration request, the Company hereby acknowledges that:

    •

    should the Commission or the Staff, acting pursuant to delegated
authority, declare the Registration Statement effective, it does not foreclose the
Commission from taking any action with respect to the Registration Statement;

    •

    the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the Registration Statement effective, does not relieve the
Company from its full responsibility for the adequacy and accuracy of the disclosure
in the Registration Statement; and

    •

    the Company may not assert comments that it has received from the Staff
and the declaration of effectiveness as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

     We understand that the Staff will consider this request as confirmation by the Company of its
awareness of its responsibilities under the federal securities laws as they relate to the
registration of the securities covered by the Registration Statement.

     We request that we be notified of the effectiveness of the Registration Statement by telephone
call to Mr. Knauss at (213) 683-9137, Mr. Kim at (213) 683-9144 or Ms. Ku at (213) 683-9243.
Please also provide a copy of the Commission’s order declaring the Registration Statement effective
to Ms. Ku via facsimile at (213) 683-4043 and via mail at Munger, Tolles & Olson LLP, 355 South
Grand Avenue, 35th Floor, Los Angeles, California 90071-1560.

* * *

U.S. Securities and Exchange Commission

September 2, 2011

Page 3 of 3

     Please direct any questions or comments regarding this acceleration request to Mr. Knauss at
(213) 683-9137, Mr. Kim at (213) 683-9144 or Ms. Ku at (213) 683-9243.

    Very truly yours,

AIR LEASE CORPORATION

    By:

/s/
Grant A. Levy

    Grant A. Levy

    Title:
    Executive Vice President, General
Counsel
and Secretary

    cc:

    Steven F. Udvar-Házy, Chairman and Chief Executive Officer

John L. Plueger, President and Chief Operating Officer

Robert B. Knauss, Munger, Tolles & Olson LLP

Mark H. Kim, Munger, Tolles & Olson LLP