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Correspondence 0001104659-23-002248 from Sun Country Airlines Holdings, Inc. (SNCY) (CIK 0001743907) (SNCY)

Sun Country Airlines Holdings, Inc. (SNCY) (CIK 0001743907)
Date: Jan. 9, 2023 · CIK: 0001743907 · Accession: 0001104659-23-002248

AI Filing Summary & Sentiment

File numbers found in text: 333-269023

Date
January 9, 2023
Author
/s/ Erin Rose Neale
Form
CORRESP
Company
Sun Country Airlines Holdings, Inc. (SNCY) (CIK 0001743907)

Letter

VIA EDGAR Division of Corporation Finance Securities and Exchange Commission Attention: Cheryl Brown Office of Energy & Transportation Sun Country Airlines Holdings, Inc. Registration Statement on Form S-3 (File No. 333-269023)

Dear Ms. Brown:

Pursuant to Rule 461 of the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-3 of Sun Country Airlines Holdings, Inc. (the “Company”) be accelerated to January 12, 2023 at 4:00 p.m. E.S.T. or as soon thereafter as may be practicable.

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 issuance of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Brian M. Janson of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3588.

*****

Very truly yours,
By:
/s/ Erin Rose Neale

Show Raw Text
CORRESP
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Sun Country Airlines Holdings, Inc.

2005 Cargo Road.

Minneapolis, MN 55450

January 9, 2023

VIA EDGAR

Division of Corporation Finance

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attention:
    Cheryl Brown

    Staff Attorney

    Office of Energy & Transportation

Sun Country Airlines Holdings, Inc.

Registration Statement on Form S-3

(File No. 333-269023)

Dear Ms. Brown:

Pursuant to Rule 461 of the Securities Act of 1933,
as amended, we hereby request that the effective date of the above-captioned Registration Statement on Form S-3 of Sun Country Airlines
Holdings, Inc. (the “Company”) be accelerated to January 12, 2023 at 4:00 p.m. E.S.T. or as soon thereafter as may be practicable.

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 issuance
of the securities covered by the Registration Statement. If you have any questions regarding the foregoing, please contact Brian M. Janson
of Paul, Weiss, Rifkind, Wharton & Garrison LLP at (212) 373-3588.

*****

    Very truly yours,

    By:
    /s/ Erin Rose Neale

    Name:
    Erin Rose Neale

    Title:
    Senior Vice President, General Counsel and Secretary