United States securities and exchange commission logo





                           April 9, 2024

       Tammy Romo
       Chief Financial Officer
       Southwest Airlines Co.
       P.O. Box 36611
       Dallas, Texas 75235

                                                        Re: Southwest Airlines
Co.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2023
                                                            Filed February 6,
2024
                                                            Response dated
March 20, 2024
                                                            File No. 001-07259

       Dear Tammy Romo:

              We have reviewed your March 20, 2024 response to our comment
letter and have the
       following comment.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

              After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our March 6,
       2024 letter.

       Form 10-K for the Fiscal Year Ended December 31, 2023

       Management's Discussion and Analysis
       Operating Revenues, page 68

   1.                                                   We understand from your
response to prior comment 1 that although you routinely
                                                        monitor industry and
customer travel patterns, including trends in business and leisure
                                                        travel, to both analyze
and forecast passenger revenues and to aid in the future
                                                        optimization of your
network and schedules, you do not regard information about business
                                                        travel revenue to be
material to investors, though would provide some explanation and
                                                        analysis if you
consider that information material in the future.

                                                        You explain that you
categorize passenger revenues by source, though identify revenue
                                                        categories based on
whether the tickets were purchased or acquired through loyalty
 Tammy Romo
Southwest Airlines Co.
April 9, 2024
Page 2
         program point redemptions. You state that these two categories
"...best depict the nature,
         amount, timing, and uncertainty of Passenger revenue and cash flow,"
though do not
         mention either of these categories in your discussion and analysis on
page 68.

         We see that a section of your website is dedicated to
corporate/business travel, covering
         various features and initiatives, such as the business travel program
booking tool,
         dedicated account management teams, coordination programs for meetings
and groups,
         and support for travel management companies, which collectively does
not clearly
         reconcile with your view of the revenue source as not material.

         Given these observations, considering your efforts at monitoring,
analyzing and
         forecasting business and leisure travel patterns, including the
associated trends and
         revenues and use of that information in resource allocation decisions,
explain to us why
         you would not also identify business and leisure ticket revenues,
individually as sources
         on page 107 to comply with FASB ASC 606-10-50-5 and 55-89 through
55-91.

         As part of your response, please identify the economic factors and
various correlations
         that you considered in identifying the non-loyalty and loyalty
passenger revenue source
         categories as depicting how the nature, amount, timing, and
uncertainty of revenue and
         cash flows are affected by economic factors; explain how you would
similarly evaluate
         economic factors and correlations for the business and leisure travel
revenue sources; and
         provide us with a schedule showing non-loyalty and loyalty passenger
revenues separately
         attributable to business and leisure ticket sales during each of the
last five fiscal years.

         If you continue to regard such information as not material for
disclosure in the notes to the
         financial statements, or in the discussion and analysis of your
results of operations,
         provide us with the analyses that you performed in formulating these
views.
       Please contact Robert Babula at 202-551-3339 or Gus Rodriguez at
202-551-3752 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameTammy Romo                                   Sincerely,
Comapany NameSouthwest Airlines Co.
                                                               Division of
Corporation Finance
April 9, 2024 Page 2                                           Office of Energy
& Transportation
FirstName LastName