May 2, 2019

Paul A. Jacobson
Chief Financial Officer
DELTA AIR LINES INC /DE/
P.O. Box 20706
Atlanta, Georgia 30320-6001

       Re: DELTA AIR LINES INC /DE/
           Form 10-K for the Year Ended December 31, 2018
           Filed February 15, 2019
           File No. 001-05424

Dear Mr. Jacobson:

       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-K for the Year Ended December 31, 2018

Note 8. Leases, page 77

1.    We note in your disclosure on page 59 that you adopted ASC 842 using the
optional
      transition method provided in ASU No. 2018-11. Please tell us how your
disclosure
      complies with ASC 842-10-65-1(jj) with respect to all periods that
continue to be in
      accordance with ASC 840.
2.    We note your disclosure that when available, you use the rate implicit in
the lease to
      discount lease payments to present value; however most of your leases do
not provide a
      readily determinable implicit rate. Please tell us if you have used the
rate implicit in the
      lease for any of your lease payment calculations. If so, describe the
circumstances and
      how you obtained the inputs to determine the rate implicit in the lease.
 Paul A. Jacobson
DELTA AIR LINES INC /DE/
May 2, 2019
Page 2
Note 9. Airport Redevelopment, page 80

3.    We note that you have entered into lease agreements related to
redevelopment projects at
      both Los Angeles International Airport and New York-LaGuardia Airport.
Please explain
      to us how you accounted for these projects and lease agreements under ASC
842.
       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 Effie Simpson at (202) 551-3346 or Claire Erlanger at
(202) 551-3301
with any questions.



                                                          Sincerely,
FirstName LastNamePaul A. Jacobson
                                                          Division of
Corporation Finance
Comapany NameDELTA AIR LINES INC /DE/
                                                          Office of
Transportation and Leisure
May 2, 2019 Page 2
cc:       Craig Meynard
FirstName LastName