March 31, 2026

Ursula Hurley
Chief Financial Officer
JetBlue Airways Corporation
27-01 Queens Plaza North
Long Island City, New York 11101

       Re: JetBlue Airways Corporation
           Form 10-K for the Fiscal Year ended December 31, 2025
           Filed February 12, 2026
           File Number 000-49728
Dear Ursula Hurley:

       We have reviewed your filing 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.

Form 10-K for the Fiscal Year ended December 31, 2025
Financial Statements
Note 1 - Summary of Significant Accounting Policies, page 69

1.     We note your accounting policy disclosure on page 70 indicating that you
depreciate
       aircraft over 25 years while using an estimated residual value of 20
percent, although
       also indicating that for "certain Airbus A320 airframes" you are using a
longer period as
       part of your "capital-light growth" initiative, although without
specifying the number of
       aircraft or the extended range being utilized for depreciation. You
provide disclosures on
       page 13 under the Operations and Cost Structure heading, and on page 43
within the
       Overview section of MD&A, associating this fleet management initiative
with recent
       plans to secure your financial future and navigate near-term demand
volatility.

       However, on page 70 of your 2024 Form 10-K you indicated that the
estimated useful
       lives for "certain Airbus A320 airframes" were extended to a range of 33
to 35 years, and
       on page 75 of your 2023 Form 10-K you indicated that the estimated
useful lives for
       "five Airbus A320 airframe" were extended to a range of 26 to 27 years,
while also
       changing the residual value to $1.5 million. We also note disclosure on
page 40 of your
 March 31, 2026
Page 2

       2024 Form 10-K, reporting that you "agreed to defer" delivery of 44
Airbus A321neo
       aircraft that were scheduled for delivery from 2025-2029, to "2030 and
beyond."

       Please expand your accounting policy disclosure to specify the numbers
of aircraft that
       have been subject to changes in the estimated service lives and residual
values during
       each of the last three fiscal years. Please indicate how the aircraft
are selected for this
       manner of change, and address the guidance in FASB ASC 250-10-50-4,
which
       requires disclosure of the affects of changes in estimates on income
from continuing
       operations, net income, and the related per-share amounts. However, if
you regard the
       affects as not material, provide us with the underlying quantitative and
qualitative
       analyses that you performed for each period in formulating your view.

       Given the nature and frequency of the changes and association with your
capital-light
       growth initiative, it appears that further disclosures should also be
provided in MD&A.
       For example, disclosures under Critical Accounting Estimates on page 53
should be
       expanded to discuss the circumstances that precipitated revisions in
each of the last three
       fiscal years, and disclosures under Liquidity and Capital Resources on
page 46 should be
       expanded to describe your capital-light growth initiative and to explain
how it relates to
       plans for securing your financial future and managing demand volatility.

       Such disclosures should clarify the financial and operational
objectives, how changes in
       the service lives of the aircraft and deferred acquisitions of aircraft
are aligned with this
       initiative, and the timeframe envisioned to deploy and measure the
results.


        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.

       Please contact Lily Dang at 202-551-3867 or Karl Hiller at 202-551-3686
if you have
questions regarding comments on the financial statements and related matters.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of Energy
& Transportation