WHEELS UP EXPERIENCE INC.
601 West 26th Street
New York, NY 10001
August 20, 2021
VIA EDGAR
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Irene Barberena-Meissner |
| Division of Corporation Finance | |
| Office of Energy & Transportation |
| RE: | Wheels Up Experience Inc. (the “Company”) |
| Registration Statement on Form S-1 | |
| File No. 333-258418 |
Ladies and Gentlemen:
Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, the Company hereby respectfully requests that the effective date of the Company’s Registration Statement on Form S-1 (File No. 333-258418) be accelerated by the Securities and Exchange Commission to 3:00 p.m., New York time, on August 24, 2021, or as soon as practicable thereafter.
We request that we be notified of such effectiveness by a telephone call to Christopher Peterson of Arnold & Porter Kaye Scholer LLP at (212) 836-8861 and that such effectiveness also be confirmed in writing.
[Signature page follows]
| Very truly yours, | ||
| Wheels Up Experience Inc. | ||
| By: | /s/ Kenneth Dichter | |
| Name: Kenneth Dichter | ||
| Title: Chief Executive Officer | ||
| cc: | Christopher Peterson |
| Arnold & Porter Kaye Scholer LLP |
