SecProbe.io

June 29, 2015

Mr. Norman Smagley
Chief Financial Officer
Gogo, Inc.
1250 North Arlington Heights Road
Itasca, IL  60143

Re: Gogo, Inc.
 Form 10 -K for Fiscal Year Ended December 31,  2014
Filed February 27, 2015
Form 10 -Q for Fiscal Year Ended March 31, 2015
Filed May 7, 2015
File No. 1-35975

Dear Mr. Smagley :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comment.  Please comply with the following comment in
future filings.  Confirm in writing that you will do so and explain to us how you intend to
comply.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response, we may have  additional comments.

Form 10 -Q for the Fiscal Quarter Ended March 31, 2015

Note 11. Commitments and Contingencies, page 15

1. Referring to the first contract disclosed under “Damages and Penalties,” we note that
you may be required to provide a refund or credit of up to $25 million under certain
circumstances to one of your airline partners , and that the refund or credit will be
eliminated in its entirety  if you complete full installation of your airline partner’s
international fleet by June 30, 2015 . Considering th at the initial deadline ha s passed ,
the status of this contingent liability is not clear.  With respect to this contingency and
any other significant contingencies, if there is at least a reasonable possibili ty that a
loss exceeding amounts already recognized may have been incurred, in your next
periodic  filing, please either disclose an estimate (or, if true, state that the estimate is

Mr. Norman Smagley
Gogo, Inc.
June 29, 2015
Page 2

 immaterial in li eu of providing qu antified amounts)  of the addition al loss or  range of
loss, or  state that such an estimate cannot be  made.  Please refer to ASC 450-20-50.

If you conclude that you cannot estimate the reasonably possible  addition al loss or range
of loss, pl ease supplementally:  (1) explain to us the  procedures you undertake on a
quarterly basis to attempt to  develop a  range of reasonably possible  loss for dis closure
and (2) for each material matter, what specific factors are causing the in ability to
estimate and when you expect those  factors to be  alleviated.  We recognize that there are
a numb er of uncertainties and pot ential outcomes associated with loss contin gencies.
Nonetheless, an effort should be  made to develop estimates for purposes of disclosure,
including  determining whi ch of the potential outcomes are reasonably possible  and what
the reasonably possible range of losses would be  for those  reasonably possible
outcomes.

 You may provide your disclosures on an aggregated basis. Please include your
 proposed disclosures in your response.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the  federal securities laws of the United States.

You may contact Christy Adams, Senior Staff Accountant, at (202) 551 -3363  or me at
(202) 551 -3810 with any questions.

Sincerely,

 /s/ Terry French for

 Carlos Pacho
Senior Assistant Chief Accountant