United States securities and exchange commission logo

                     November 22, 2022

       Gerald Laderman
       Executive Vice President and Chief Financial Officer
       United Airlines Holdings, Inc.
       233 South Wacker Drive
       Chicago, IL 60606

                                                        Re: United Airlines
Holdings, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 18,
                                                            File No. 001-06033

       Dear Gerald Laderman:

              We have completed our review of your filing. 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.


                     Division of Corporation Finance

                     Office of Energy & Transportation