December 12, 2005 Mail Stop 3651 BY U.S. Mail and Facsimile [ (914) 701 - 8081 ] Mr. Jeffrey H. Erickson President and Chief Executive Officer ATLAS AIR WORLDWIDE HOLDINGS, INC. 2000 Westchester Avenue Purchase, New York 10577 	Re:	Atlas Air Worldwide Holdings, Inc. Form 10-K for Fiscal Year Ended December 31, 2004 		File No. 1-16545 Dear Mr. Erickson: 	We have completed our review of your Form 10-K and have no further comments at this time. Sincerely, 								David R. Humphrey 								Accounting Branch Chief ?? ?? ?? ?? Jeffrey H. Erickson Atlas Worldwide Holdings, Inc. November 21, 2005 Page 3