United States securities and exchange commission logo February 1, 2021 Scott M. Haralson Senior Vice President and Chief Financial Officer Spirit Airlines, Inc. 2800 Executive Way Miramar, FL 33025 Re: Spirit Airlines, Inc. Amended Form 10-K for Fiscal Year Ended December 31, 2019 Filed April 16, 2020 File No. 001-35186 Dear Mr. Haralson: 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 Energy & Transportation