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                              March 19, 2024

       Jessica Betjemann
       Executive Vice President and Chief Financial Officer
       Gogo Inc.
       105 Edgeview Drive, Suite 300
       Broomfield, CO 80021

                                                        Re: Gogo Inc.
                                                            Form 10-K for the
year ended December 31, 2023
                                                            File No. 001-35975

       Dear Jessica Betjemann:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments.

              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 year ended December 31, 2023

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 42

   1.                                                   We note for some of
your line items, such as cost of service revenue, engineering, design
                                                        and development
expenses and general and administrative expenses, that fluctuations
                                                        between periods are due
to two or more factors. We also note your reference to changes
                                                        being due "primarily"
to these factors. Where a material change is attributed to two or
                                                        more factors, including
any offsetting factors, revise to describe the contribution of each
                                                        factor in quantified
terms. Please also revise to use more definitive terminology, rather
                                                        than general or vague
terms such as "primarily," to describe each contributing factor.
                                                        Refer to Item 303(b) of
Regulation S-K and Section III.D of SEC Release No. 33-6835.
 Jessica Betjemann
FirstName
Gogo Inc. LastNameJessica Betjemann
Comapany
March       NameGogo Inc.
       19, 2024
March2 19, 2024 Page 2
Page
FirstName LastName
Non-GAAP Measures, page 44

2.       We note your adjustment for the proceeds from (purchase of) interest
rate caps in
         calculating your free cash flow measure. Please explain your basis for
this adjustment and
         tell us what you are intending to convey. Also, tell us how you
considered the prohibitions
         in Item 10(e)(1)(ii)(A) of Regulation S-K regarding this non-GAAP
adjustment. As part of
         your response, tell us how you determined the proceeds from (purchase
of) interest rate
         caps is an investing cash flow and refer to the authoritative guidance
that supports your
         presentation.
Consolidated Financial Statements
Note 3. Revenue Recognition, page 67

3.       We note you expect to recognize the majority of your remaining
performance obligations
         over a period from two to 10 years. Please revise to breakdown this
amount, either
         quantitatively or qualitatively, into smaller time bands that better
indicate the timing of
         revenue recognition. Also, consider disclosing how much you expect to
recognize in the
         next 12-months. Refer to ASC 606-10-50-13.
       In closing, 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 Brittany Ebbertt at 202-551-3572 or Christine Dietz at
202-551-3408 with
any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Technology
cc:      Crystal Gordon