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October 5, 2023
Ryan Goepel
Chief Financial Officer
Global Crossing Airlines Group Inc.
4200 NW 36th Street
Building 5A
Miami International Airport
Miami, Florida 33166
Re:Global Crossing Airlines Group Inc.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed March 10, 2023
File No. 000-56409
Dear Ryan Goepel:
            We have reviewed your September 21, 2023 response to our comment letter and have the
following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our September 7, 2023
letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 24
1.We note that revisions proposed in response to prior comment 2 include a revenue
variance analysis in which you attribute the change in revenues to increases in volume,
indicating block hours increased 416% and average available aircraft increased 448%,
though without identifying the effects of any changes in price. However, based on the
information you have provided it appears that revenue per block hour of $11,204 for 2022
reflects an increase of 32% from revenue per block hour of $8,516 for 2021.

Please further expand your proposed revisions to more clearly address the requirements in

 FirstName LastNameRyan Goepel
 Comapany NameGlobal Crossing Airlines Group Inc.
 October 5, 2023 Page 2
 FirstName LastNameRyan Goepel
Global Crossing Airlines Group Inc.
October 5, 2023
Page 2
Item 303(b)(2)(iii) of Regulation S-K, to describe the extent to which changes in revenues
are attributable to changes in prices and separately to changes in the volume or amount of
goods or services being sold.
2.We note that in response to prior comment three you proposed changes regarding specific
adjustments related to your calculations of non-GAAP measures though did not address
the concern of disclosing non-GAAP measures with greater prominence than GAAP
measures.

For example, the headline and the first two paragraphs of your earnings release filed on
Form 8-K on March 14, 2023 include a discussion of non-GAAP measures though do not
include any comparable discussion of GAAP measures such as operating loss and net
loss.

Please refrain from presenting non-GAAP measures, including any discussion and
analysis of the non-GAAP measures, in advance of and in the absence of the most directly
comparable GAAP measure and a corresponding discussion and analysis, in future
earning releases, investor presentations, and periodic reports.

You may refer to the answer to Question 102.10 of our Non-GAAP Compliance and
Disclosure Interpretations at https://www.sec.gov/ corpfin/non-gaap-financial-measures if
you require further clarification. These requirements would also pertain to an earnings
release headline or caption that includes a non-GAAP measure.
3.We note that revisions proposed in response to prior comment four include language
stating that you believe it is important "...to highlight start-up expenses, creating an asset
to support future revenue," which seems to suggest the costs are both expensed and
capitalized.

Please further revise this proposed disclosure to disassociate the term asset from your
discussion of start-up costs that are being expensed.
4.We note your response to prior comment five indicating you believe that EBITDAR is
useful as it allows for the comparison of a normalized metric among different sized
airlines that purchase and/or lease their aircraft.  Please provide such clarification for
investors in your future earnings releases.
Liquidity and Capital Resources , page 25
5.We note that revisions proposed in response to prior comment six indicate that additional
projected aircraft in 2023 include four that are under LOI.

Please further clarify your use of the acronym and if this is a reference to a letter of intent,
disclose the salient terms of the arrangement that are being contemplated, including the
timeframe and a discussion of any uncertainties that will need to be resolved.

 FirstName LastNameRyan Goepel
 Comapany NameGlobal Crossing Airlines Group Inc.
 October 5, 2023 Page 3
 FirstName LastName
Ryan Goepel
Global Crossing Airlines Group Inc.
October 5, 2023
Page 3
Note 2 - Basis of Presentation and Summary of Significant Accounting Policies
Revenue Recognition , page 37
6.We note that you include certain draft disclosures addressing some but not all of the
concerns identified in prior comment eight. Please address the following;

•Further revise to disclose any obligations for refunds or similar obligations pursuant
to FASB ASC 606-10-50-12(d), or to clarify if there are none;

•Disclose your policy of accounting for customer deposits to comply with FASB
ASC 235-10-50-1; and

•Clarify your rationale for distinguishing customer deposits from deferred revenue.
            Please contact John Cannarella at 202-551-3337 or Karl Hiller at 202-551-3686 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation