September 6, 2018 Brandon Pedersen Executive Vice President and Chief Financial Officer Alaska Air Group, Inc. 19300 International Boulevard Seattle WA 98188 Re: Alaska Air Group, Inc. Form 10-K For the Fiscal Year Ended December 31, 2017 Filed February 15, 2018 File No. 001-08957 Dear Mr. Pedersen: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Transportation and Leisure