SecProbe.io

October 24, 2018
Craig I. Felenstein
Chief Financial Officer
Lindblad Expeditions Holdings, Inc.
96 Morton Street, 9th Floor
New York, New York 10014
Re:Lindblad Expeditions Holdings, Inc.
Form 10-K for the Year Ended December 31, 2017
Form 10-Q for the Quarter Ended June 30, 2018
File No. 001-35898
Dear Mr. Felenstein:
            We have reviewed your October 1, 2018 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
September 20, 2018 letter.
Response dated October 1, 2018
Form 10-Q for the Quarter Ended June 30, 2018
Revenue Recognition, page 7
1.We note your response to prior comment 3.  Please provide us with your analysis
regarding how you determined gross reporting for airfare was appropriate pursuant to
ASC 606-10-55- 36 through 39.  Specifically address the following items in your
response:
•How you considered the definition of control and how you are directing any third
party providers;
•How you considered the $50 per person charge for the service of booking airline

 FirstName LastNameCraig I. Felenstein
 Comapany NameLindblad Expeditions Holdings, Inc.
 October 24, 2018 Page 2
 FirstName LastName
Craig I. Felenstein
Lindblad Expeditions Holdings, Inc.
October 24, 2018
Page 2
reservations that we note from your website;
•Describe the types of promises in your contract to provide airfare based on the nature
of the flights included in your excursions to your customers (i.e., commercial versus
chartered flights), and;
•Tell us how you price airfare in your excursion packages.
            You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at 202-551-3379
with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure