Mail Stop 3628

                                                           February 27, 2019

Via E-mail
David J. Hoberman
President
American Express Receivables Financing Corporation VIII LLC
200 Vesey Street
30th Floor, Room 505A
New York, New York 10285

       Re:    American Express Issuance Trust II
              American Express Receivables Financing Corporation VIII LLC
              Registration Statement on Form SF-3
              Filed February 1, 2019
              File Nos. 333-229493 and 333-229493-01

Dear Mr. Hoberman:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form SF-3

Form of Prospectus

Asset Representations Review--Other Matters Relating to the Asset
Representations Reviewer,
page 129

   1. We note that your form of prospectus describes the manner, but not the
amount, in which
      the asset representations reviewer is compensated. Please revise your
disclosure to
      include the amounts payable to the asset representations reviewer
pursuant to the asset
      representations review agreement. Refer to Item 1109(b)(4) of Regulation
AB.
 David J. Hoberman
American Express Receivables Financing Corporation VIII LLC
February 27, 2019
Page 2


Item 14. Exhibits.

      2. We note that your exhibit list indicates that confidential information
has been omitted
         from Exhibits 4.11.11 and 4.11.12. It appears that these exhibits have
been filed in full
         without redactions. If true, please delete the notations to Exhibits
4.11.11 and 4.11.12 or
         advise.

        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.

        Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Benjamin Meeks, Special Counsel, at (202) 551-7146 or me
at (202)
551-3313 if you have any questions.


                                                               Sincerely,

                                                               /s/ Rolaine S.
Bancroft

                                                               Rolaine S.
Bancroft
                                                               Senior Special
Counsel
                                                               Office of
Structured Finance


cc:      David A. Kanarek, Esq.
         American Express Company

         Alan M. Knoll, Esq.
         Orrick, Herrington & Sutcliffe LLP