SEC Company Response from Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710) (FLYYQ) — Nov 18, 2010
Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710)
Date: Nov. 18, 2010 · CIK: 0001498710 · Accession: 0001193125-10-263488
AI Filing Summary & Sentiment
File numbers found in text: 333-169474
Referenced dates: November 17, 2010
Letter
Supplemental Response Letter to the SEC
140 Scott Drive
Menlo Park, California 94025
Tel: +1.650.328.4600 Fax: +1.650.463.2600
www.lw.com
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November 18, 2010
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United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Lynwood Shenk
Confidential Treatment Requested
Under 17 C.F.R. §§ 200.80(b)(4), 200.83 and 230.406
Re: Spirit Airlines, Inc.
Amendment No. 2 to Registration Statement on Form S-1
File No. 333-169474
Ladies and Gentlemen:
On behalf of Spirit Airlines, Inc. (the “Company”), in connection with the submission of a letter dated November 17, 2010 (the “Letter”) to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in response to the Commission’s comments sent by facsimile on November 9, 2010 regarding the Company’s above-referenced Registration Statement on Form S-1, which was initially filed with the Commission on September 17, 2010 and amended by Amendment No. 1 filed on October 28, 2010 and Amendment No. 2 filed on November 18, 2010 (as amended, the “Registration Statement”), the undersigned respectfully submits this supplemental response. Pursuant to our discussion with the Staff on November 12, 2010 and as referenced in the Letter, we are hereby providing, subject to a request for confidential treatment, the underlying analysis relating to the Company’s accounting treatment for maintenance reserve payments, which is attached hereto as Exhibit A.
Please do not hesitate to contact me by telephone at (650) 463-2643 or by fax to my attention at (650) 463-2600 with any questions or comments regarding this correspondence.
Very truly yours,
/s/ Anthony J. Richmond
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filename1.htm
Supplemental Response Letter to the SEC
140 Scott Drive
Menlo Park, California 94025
Tel:
+1.650.328.4600 Fax: +1.650.463.2600
www.lw.com
FIRM / AFFILIATE OFFICES
Abu Dhabi
Moscow
Barcelona
Munich
Beijing
New Jersey
Brussels
New York
Chicago
Orange County
Doha
Paris
Dubai
Riyadh
Frankfurt
Rome
Hamburg
San Diego
Hong Kong
San Francisco
November 18, 2010
Houston
Shanghai
London
Silicon Valley
Los Angeles
Singapore
Madrid
Tokyo
VIA EDGAR AND HAND DELIVERY
Milan
Washingtn, D.C.
United States Securities and
Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-6010
Attention: Lynwood Shenk
Confidential Treatment Requested
Under 17 C.F.R. §§
200.80(b)(4), 200.83 and 230.406
Re: Spirit Airlines, Inc.
Amendment No. 2 to Registration Statement on Form S-1
File No.
333-169474
Ladies and Gentlemen:
On behalf of Spirit Airlines, Inc. (the “Company”), in connection with the submission of a letter dated November 17, 2010 (the “Letter”) to the staff
(the “Staff”) of the Securities and Exchange Commission (the “Commission”) in response to the Commission’s comments sent by facsimile on November 9, 2010 regarding the Company’s
above-referenced Registration Statement on Form S-1, which was initially filed with the Commission on September 17, 2010 and amended by Amendment No. 1 filed on October 28, 2010 and Amendment No. 2 filed on November 18, 2010
(as amended, the “Registration Statement”), the undersigned respectfully submits this supplemental response. Pursuant to our discussion with the Staff on November 12, 2010 and as referenced in the Letter, we are hereby
providing, subject to a request for confidential treatment, the underlying analysis relating to the Company’s accounting treatment for maintenance reserve payments, which is attached hereto as Exhibit A.
Please do not hesitate
to contact me by telephone at (650) 463-2643 or by fax to my attention at (650) 463-2600 with any questions or comments regarding this correspondence.
Very truly yours,
/s/ Anthony J. Richmond
Anthony J. Richmond
of LATHAM & WATKINS LLP
cc:
B. Ben Baldanza, Spirit Airlines, Inc.
Thomas C. Canfield, Spirit Airlines, Inc.
Leslie N. Silverman, Cleary Gottlieb Steen & Hamilton LLP
Exhibit A
*****
***** Confidential portions
of the material have been omitted and filed separately with the Securities and Exchange Commission.