November 2, 2018

Shannon Okinaka
Chief Financial Officer
Hawaiian Holdings, Inc.
3375 Koapaka Street, Suite G-350
Honolulu, HI 96819

       Re: Hawaiian Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Form 10-Q for the Quarter Ended September 30, 2018
           File No. 001-31443

Dear Ms. Okinaka:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-Q for the Quarter Ended September 30, 2018

Notes to Consolidated Financial Statements
4. Revenue Recognition, page 12

1.    Please tell us your consideration of disclosing any obligations for
returns, refunds and
      other similar obligations pursuant to ASC 606-10-50-20(d).
Frequent Flyer Revenue, page 13

2.    We note that you offer various membership levels including Premier, Gold
and
      Platinum under your HawaiianMiles Membership Program. Please tell us if
you consider
      the complimentary or discounted services offered under these various
tiers as marketing
      incentives or as material rights accounted for as a separate performance
obligation
      pursuant to ASC 606-10-55-42 to 43.
 Shannon Okinaka
Hawaiian Holdings, Inc.
November 2, 2018
Page 2
3.       We note your disclosure that you recognize revenue for marketing and
brand performance
         obligations when HawaiianMiles members use their co-brand credit card
and the resulting
         mileage credits are issued to them, which best correlates with the
company's performance
         toward satisfying the obligation. Please tell us the basis of your
conclusion that timing of
         revenue recognition should be based on the customer's use of the
credit card. In your
         response, tell us the separately identified performance obligations
associated with your co-
         branded credit card arrangements and describe any significant
judgments made in
         determining this conclusion.
4.       We note your disclosure regarding the balance of the contract
liability balance for the
         frequent flyer liability on page 14, which is comprised of both
short-term and long-term
         amounts. Please tell us how you determined this disclosure is
compliant with Rule 5-02
         of Regulation S-X.
       In closing, 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.

      You may contact Melissa Gilmore at (202) 551-3777 or Melissa Raminpour at
(202) 551-
3379 with any questions.



FirstName LastNameShannon Okinaka                              Sincerely,
Comapany NameHawaiian Holdings, Inc.
                                                               Division of
Corporation Finance
November 2, 2018 Page 2                                        Office of
Transportation and Leisure
FirstName LastName