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                           July 28, 2021

       Edward J. Wegel
       Chairman and Chief Executive Officer
       Global Crossing Airlines Group Inc.
       4200 NW 36th Street
       Building 5A
       Miami International Airport
       Miami, FL 33166

                                                        Re: Global Crossing
Airlines Group Inc.
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted July 15,
2021
                                                            CIK No. 0001846084

       Dear Mr. Wegel:

             We have reviewed your amended draft registration statement and
have the following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. If you do not believe our comments apply to your facts and
circumstances or do not
       believe an amendment is appropriate, please tell us why in your
response.

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Draft Registration Statement on Form S-1 filed on July 15, 2021

       Summary of the Prospectus
       Launch cargo charter flights with A321P2F (Passenger to Freighter), page
4

   1.                                                   We note your response
to our prior comment 5. Please balance your disclosure to
                                                        describe the material
risks you retain or assume under the ACMI/Wet Lease charter
                                                        operations.
 Edward J. Wegel
FirstName  LastNameEdward   J. Wegel
Global Crossing Airlines Group Inc.
Comapany
July       NameGlobal Crossing Airlines Group Inc.
     28, 2021
July 28,
Page  2 2021 Page 2
FirstName LastName
Location of Operations Bases, page 5

2.       We note your response to our prior comment 7 and revised risk factor
disclosure. Please
         revise this section to clarify that while the Airport Use Agreement
with Miami
         International Airport permits operating charter flights out of
Concourse E, it does
         not guarantee availability of boarding gates or landing slots at that
airport.
Risk Factors
We must obtain additional financing to complete the FAA certification process,
page 25

3.       Please reconcile your revised disclosure on page 4 that GlobalX
currently has over $10
         million in available cash along with $2 million in deposits and
prepaids, and that these
         cash amounts are sufficient available capital to achieve the
milestones referenced in that
         section, with your risk factor disclosure on page 25 that you must
obtain additional
         financing to complete the FAA certification process.
Description of Capital Stock, page 81

4.       Please disclose all material terms regarding the voting rights,
dividend rights and
         conversion rights of the Class A Non-Voting Common Stock and Class B
Non-Voting
         Common Stock. In that regard, we note the rights set forth in Article
IV of the Amended
         and Restated Certificate of Incorporation filed as Exhibit 3.1.
Selling Stockholders, page 89

5.       With respect to the shares in the table to be resold by Ascent Global
Logistics, Inc. and
         Cordia Management Inc., please revise to clarify which shares are
being offered for resale
         pursuant to this prospectus, and which shares will be beneficially
owned after the offering.
         In that regard, it appears that there is a typographical error with
respect to the placement
         of the related data in the selling stockholders table.
Note 3 Deferred Financing Fee, page F-34

6.       We note that you expanded your accounting policy note to include a
definition of foreign
         currency transactions in response to prior comment 25. We had
previously observed that
         your CAD dollar denominated note was reported on your balance sheet at
$1,570,800 as
         of both December 31, 2020 and March 31, 2021, which seems to imply
that either 1) there
         was no change in the US/CAD dollar exchange rate during the quarter
ended March 31,
         2021, or 2) that an entry to record the foreign currency gain or loss
for the three months
         ended March 31, 2021 was omitted.

         However, on page 37 you state that "The Company recorded a foreign
exchange gain for
         the three months ended March 31, 2021 in the amount of $136,808,
compared to $Nil for
         the three months ended March 31, 2020." Please provide us with details
regarding the
         composition of the foreign currency transaction gain reported in MD&A
and explain why
         your CAD dollar denominated liability does not appear to have been
adjusted pursuant to
 Edward J. Wegel
Global Crossing Airlines Group Inc.
July 28, 2021
Page 3
      FASB ASC 830-25-1 and 2.
Note 10 Share Capital and Additional Paid-In Capital Authorized, page F-37

7.    We note your response to prior comment 26 and disclosures on pages F-13
stating "the
      Company recognized the issuance of the restricted and unregistered share
capital based on
      the assumption of net monetary liabilities, along with a
recapitalization. On the date of the
      Transaction, net liabilities of $779,984 were assumed." You also state
"At the time of the
      merger Canada Jetlines had a working capital deficit of $566,746 and
Global Crossing
      Airlines had a zero working capital deficit. Assets consisted of cash on
hand and liabilities
      primarily related to vendor payables and loans payable to related
parties." However, it
      remains unclear how the net liabilities assumed reconciles to the
$1,286,533 debit to
      APIC, and it is unclear which entity you are referring to with the last
sentence cited above.

      On page F-20 you also state that "The consolidation resulted in each
shareholder of the
      Company receiving one post-consolidation share for every ten
pre-consolidation common
      shares held, for a total of 8,529,853 common shares." However, on page
F-6 you report
      8,482,990 shares deemed to be issued from the standpoint of Global USA,
i.e.
      representing the outstanding share capital of the legal entity prior to
the transaction.

      Please further revise your disclosures to resolve these inconsistencies
and to include
      details sufficient to understand how the net liability position of Canada
Jetlines, Ltd. is
      reflected in your equity adjustment. Please also submit for our review a
reconciliation
      between the individual assets and liabilities recognized and those
reflected in the capital
      deficit of CAD$ 1,417,114 reported by this entity on SEDAR as of March
31, 2020, and
      explanations for all material variations.
Exhibits

8.    Please file as an exhibit the Certificate of Designations, Powers,
Preferences and Rights
      for the Class A Non-Voting Common Stock that you reference on page 47.
        You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Karl Hiller,
Accounting Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the
financial statements and related matters. Please contact Anuja A. Majmudar,
Attorney-Advisor,
at (202) 551-3844 or, in her absence, Laura Nicholson, Special Counsel, at
(202) 551-3584 with
any other questions.



                                                            Sincerely,
FirstName LastNameEdward J. Wegel
                                                            Division of
Corporation Finance
Comapany NameGlobal Crossing Airlines Group Inc.
                                                            Office of Energy &
Transportation
July 28, 2021 Page 3
cc:       Martin T. Schrier
FirstName LastName