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Delta
Air Lines, Inc.
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Post
Office Box 20706
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Atlanta,
Georgia 30320-6001 U.S.A.
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March
1, 2007
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VIA
EDGAR
Cecilia
D. Blye
Chief,
Office of Global Security Risk
U.S.
Securities and Exchange Commission
100
F
Street, N.E.
Washington,
D.C. 20549-5546
| Re: |
Delta
Air Lines, Inc.
Form
10-K for the Fiscal Year Ended December 31, 2005
Filed
March 27, 2006
File
No. 1-05424
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Dear
Ms.
Blye:
This
is
in response to the Staff’s letter dated February 27, 2007, regarding Delta’s
Form 10-K for the fiscal year ended December 31, 2005. For your convenience,
we
have included in this letter the Staff’s comment before providing our response
to that comment.
| 1. |
We
note the representation in your response that “Delta employees
occasionally exceed their authority and issue interline tickets on
Delta
ticket stock for travel to or from Cuba.” Please expand your materiality
analysis to address whether such activity by your employees may expose
you
to liability under U.S. sanctions provisions and thus present a risk
to
your reputation.
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As
discussed in our response letter to the Staff dated February 13, 2007, Delta
does not operate any flights to or from Cuba. During the period from 2005
through 2006, Delta has identified only two instances in which Delta employees,
in violation of Delta’s explicit compliance policy, improperly used Delta ticket
stock to issue a prohibited flight segment to/from Havana on another airline.
Delta has taken steps to discipline these employees consistent with its policy
and to voluntarily disclose these matters to the U.S. Treasury’s Office of
Foreign Assets Control. The total interline commission revenue received by
Delta
as a result of these transactions was $8.50. It is unclear whether or to what
extent such actions in violation of Delta policy might subject Delta to
liability under U.S. sanctions provisions, but, in any case, there are
substantial mitigating factors. In our view, this matter does not present any
material risk to Delta’s reputation.
If
you
have any questions, or would like any additional information, please let me
know.
Very
truly yours,
/s/
Kenneth F. Khoury
Executive
Vice President - General Counsel
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cc:
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Gerald
Grinstein
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