August 30, 2024
Vladimir Galkin
Investor
JETBLUE AIRWAYS CORP
10900 NW 97th Street, #102
Miami, FL 33178
Re: JETBLUE AIRWAYS CORP
Schedule 13G filed April 22, 2024, as amended
Filed by Vladimir Galkin, Angelica Galkin, and the Angelica Galkin
Revocable
Trust
File No. 005-78219
Dear Vladimir Galkin:
We have reviewed your filing and have the following comment. In our
comment, we may
ask you to provide us with information so we may better understand your
disclosure.
Please respond to this comment by providing the requested information
or advise us as
soon as possible when you will respond. If you do not believe our comment
applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional
comments.
Schedule 13G filed April 22, 2024, as amended
General
1. We understand that, in connection with your investment in JetBlue
Airways Corporation
(the "Company"), you have expressed to the Company an interest in
obtaining a board
seat. We also note that, with respect to your investment, you have
disclosed your
beneficial ownership on Schedule 13G, have indicated that your Schedule
13G filing has
been made pursuant to Rule 13d-1(c), and have made a corresponding
certification under
Item 10 stating that your investment was not made for the purpose of
or with the effect
of changing or influencing the control of the issuer. Please provide
a detailed legal
analysis reconciling your expressed interest in obtaining a board seat
with your filing of a
Schedule 13G, or, alternatively, file a Schedule 13D with respect to
your investment.
We remind you that the filing persons are responsible for the accuracy
and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
August 30, 2024
Page 2
Please direct any questions to David Plattner at 202-551-8094.
Sincerely,
Division of
Corporation Finance
Office of Mergers and
Acquisitions