May 13, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail

Mr. Robert W. Zoller
Chief Executive Officer and President
Kitty Hawk, Inc.
1515 West 20th Street
P.O. Box 612787
DFW International Airport, Texas 75261

RE:	Kitty Hawk, Inc. (the "Company")
	Form 10-K for the year ended December 31, 2004
	File No. 0-14275

Dear Mr. Zoller:

We have reviewed your response letter dated April 25, 2005 and
have
the following comment.  The primary purpose of this comment is to
request that you provide us with supplemental information so we
may
better understand your disclosure.  After reviewing this
information,
we may or may not raise additional comments.

Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have with regard to our comment or on any other
aspect of our review.  Feel free to call us at the telephone
numbers
listed at the end of this letter.

Please respond to our comment within fifteen (15) business days.
Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
also be submitted in electronic form, under the label "corresp"
with
a copy to the staff.










Form 10-K for the Fiscal Year-ended 12/31/2004

Item 8.   Financial Statements and Supplementary Data

16.  Business Segment Data, page F-29

1. We note that your response to our prior comment number 16
indicates that the asset balances allocated to each of your
segments
have fluctuated primarily due to intercompany costs and debt.  As
you
state that there have been no changes in Kitty Hawk`s methodology
for
allocating costs for the periods presented and the largest
intercompany expense for each of the periods presented appears to
have related to your Cargo Airline segment supporting your
Scheduled
Freight Network segment, please explain to us in detail how
intercompany costs and debt have resulted in such significant
fluctuations in your allocation of assets between segments.  For
example, please explain why the total assets of your Scheduled
Freight Network have increased from $6,278 at December 31, 2002 to
$15,842 at December 31, 2004, and the total assets of your Cargo
Airline have declined from $20,155 at December 31, 2002 to $7,205
at
December 31, 2004.  We may have further comment upon the receipt
of
your response.

Other

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require.  Since
the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

You may contact Jeffrey Sears at (202) 551-3302 if you have
questions
regarding comments on the financial statements and related
matters.
Please contact the undersigned at (202) 551-3813 with any other
questions.


								Sincerely,


								Linda Cvrkel
								Branch Chief


Via facsimile:  Randy S. Leiser, CFO

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Mr. Robert W. Zoller
Kitty Hawk, Inc.
May 13, 2005
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