July 31, 2019

Alexandre Wagner Malfitani
Chief Financial Officer
AZUL SA
Edif cio Jatob , 8th floor, Castelo Branco Office Park
Avenida Marcos Penteado de Ulh a Rodrigues, 939
Tambor , Barueri, S o Paulo, SP 06460-040
Federative Republic of Brazil

       Re: AZUL SA
           Form 20-F for Fiscal Year Ended December 31, 2018
           Response Dated July 18, 2019
           File No. 001-38049

Dear Mr. Malfitani :

       We have reviewed your July 18, 2019 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to
comments in our
July 3, 2019 letter.

Form 20-F for Fiscal Year Ended December 31, 2018

Item 3. Key Information
Statement of Operations Data, page 9

1.     We note your response to our prior comment one. Please revise to add a
footnote to this
       reconciliation table to disclose the nature of and the quantification of
items included in the
       adjustment titled "Non-recurring events."

       We note that you have included an adjustment for the "loss of revenue
from use of such
       jets estimated at R$51.2 million." This adjustment appears to be
calculated using tailored
       revenue recognition and measurement methods. Please tell us how you
determined that
 Alexandre Wagner Malfitani
AZUL SA
July 31, 2019
Page 2
         your disclosure of this measure complies with Question 100.04 of
staff's Compliance and
         Disclosure Interpretations ("C&DI") on "Non-GAAP Financial Measures."
Alternatively,
         please revise to remove this adjustment.

         Additionally, it appears that the reconciliation of EBITDA to Adjusted
EBITDA for 2018
         in both currencies is not calculated correctly. Please revise
accordingly. Please note that
         this also impacts your calculation of Adjusted EBITDAR and Adjusted
EBITDAR
         margin.
Item 5   Operating and Financial Review and Prospects
Disclosure of Contractual Obligations, page 103

2.       We note your response to our prior comment two. Your purchase
commitments for the
         acquisition of aircraft of R$14.9 billion appear to meet the
definition of purchase
         obligations per Form 20-F Item 5. F. 2 which states "purchase
obligation means an
         agreement to purchase goods or services that is enforceable and
legally binding on the
         company that specifies all significant terms, including: fixed or
minimum quantities to be
         purchased; fixed, minimum or variable price provisions; and the
approximate timing of
         the transaction". Accordingly please revise your contractual
obligations disclosure to
         include these commitments for aircraft acquisition within the table.

         We note from your response that interest in the table is accrued and
unpaid interest related
         to loans and financings contracted by the Company. However, as the
contractual
         obligation table is aimed at increasing transparency of cash flow, we
believe that
         registrants should include scheduled interest payments in the table.
To the extent that
         interest rates are variable and unknown, you may use judgment to
determine
         which interest rates to use. Accordingly, please revise to include
         the scheduled interest payments and footnote disclosure discussing
what interest rate was
         used and how it was determined.

         Please provide us with a copy of your intended revised disclosure.
       You may contact Aamira Chaudhry at 202-551-3389 or Lyn Shenk at
202-551-3380 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameAlexandre Wagner Malfitani                   Sincerely,
Comapany NameAZUL SA
                                                               Division of
Corporation Finance
July 31, 2019 Page 2                                           Office of
Transportation and Leisure
FirstName LastName