SPIRIT AIRLINES, INC.

2800 EXECUTIVE WAY

MIRAMAR FLORIDA 33025

January 17, 2012

VIA EDGAR AND FACSIMILE (703-813-6967)

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention:	Tonya Aldave
	Julie F. Rizzo, Attorney-Advisor

Re:	Spirit Airlines, Inc.
	Registration Statement on Form S-1 (File No. 333-178336)

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, we hereby request acceleration by the Securities and Exchange Commission (the “Commission”) of the effective date of the Registration Statement on Form S-1 (Registration No. 333-178336) (the “Registration Statement”) of Spirit Airlines, Inc. (the “Company”). We respectfully request that the Registration Statement become effective as of 2:00 p.m., Washington, D.C. time, on January 19, 2012, or as soon as practicable thereafter. Once the Registration Statement has been declared effective, please orally confirm that event with our counsel, Latham & Watkins LLP, by calling Anthony J. Richmond at (650) 463-2643.

The Company acknowledges the following:

• should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Thank you for your assistance in this matter.

Very truly yours,
SPIRIT AIRLINES, INC.
By:	/s/ Thomas Canfield
	Thomas Canfield Senior Vice President, General Counsel and Secretary