SEC Company Response from Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710) (FLYYQ) — Nov 22, 2010
Spirit Aviation Holdings, Inc. (FLYY) (CIK 0001498710)
Date: Nov. 22, 2010 · CIK: 0001498710 · Accession: 0001193125-10-266051
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-169474
Letter
VIA EDGAR AND HAND DELIVERY United States Securities and Exchange Commission Division of Corporation Finance 047685-0001 Re: Spirit Airlines, Inc. Registration Statement on Form S-1 File No. 333-169474
Dear Ms. Bednarowski:
On behalf of Spirit Airlines, Inc. (the “Company”), enclosed please find a copy of the revised artwork intended to be included on the inside front and inside back cover of the preliminary prospectus to be included in the next pre-effective amendment to the registration statement and distributed to potential investors in the offering. This revised artwork is intended to respond to the comments of the Staff as expressed in the telephone call you placed to me on Friday, November 19, 2010. In further response to your comments, I can confirm to you on behalf of the Company that all of the new routes identified on the route map have been publicly announced and are included in the Company’s published flight schedule. The new routes will also be identified in the next pre-effective amendment to the registration statement.
Please do not hesitate to contact me at (650) 463-2643 if you have any questions regarding the foregoing.
Very truly yours,
/s/ Anthony J. Richmond
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CORRESP 1 filename1.htm Correspondence 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 November 22, 2010 Doha Paris Dubai Riyadh Frankfurt Rome VIA EDGAR AND HAND DELIVERY Hamburg San Diego Hong Kong San Francisco Houston Shanghai London Silicon Valley United States Securities and Exchange Commission Los Angeles Singapore Division of Corporation Finance Madrid Tokyo 100 F Street, N.E. Milan Washington, D.C. Washington, D.C. 20549-6010 Attn: Sonia Bednarowski 047685-0001 Re: Spirit Airlines, Inc. Registration Statement on Form S-1 File No. 333-169474 Dear Ms. Bednarowski: On behalf of Spirit Airlines, Inc. (the “Company”), enclosed please find a copy of the revised artwork intended to be included on the inside front and inside back cover of the preliminary prospectus to be included in the next pre-effective amendment to the registration statement and distributed to potential investors in the offering. This revised artwork is intended to respond to the comments of the Staff as expressed in the telephone call you placed to me on Friday, November 19, 2010. In further response to your comments, I can confirm to you on behalf of the Company that all of the new routes identified on the route map have been publicly announced and are included in the Company’s published flight schedule. The new routes will also be identified in the next pre-effective amendment to the registration statement. Please do not hesitate to contact me at (650) 463-2643 if you have any questions regarding the foregoing. Very truly yours, /s/ Anthony J. Richmond Anthony J. Richmond of LATHAM & WATKINS LLP Enclosures cc: B. Ben Baldanza, Spirit Airlines, Inc. Thomas C. Canfield, Spirit Airlines, Inc. Leslie N. Silverman, Cleary Gottlieb Steen & Hamilton LLP