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                              October 28, 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
                                                            Response dated
October 7, 2022
                                                            File No. 001-06033

       Dear Gerald Laderman:

              We have reviewed your October 7, 2022 response to our comment
letter 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 these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 7, 2022 letter.

       Response dated October 7, 2022

       Risk Factors, page 18

   1.                                                   We note your response
to prior comment 3 and reissue it in part. Please expand your
                                                        disclosure to discuss
risks related to climate change market trends that may alter business
                                                        opportunities in
greater detail, including, for example, changes in customer demand
                                                        related to greenhouse
gas emissions.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
       35

   2.                                                   We note your response
to prior comment 6. Please expand your disclosure to address
                                                        reputational risks that
may result from your current operations that produce material
                                                        greenhouse gas
emissions.
 Gerald Laderman
United Airlines Holdings, Inc.
October 28, 2022
Page 2
3.       We note your response to prior comment 7 states that weather-related
damages to your
         property and operations were not material during the years covered by
your Form 10-K
         and that you note by way of example the costs related to the 2021
winter storm that took
         place across Texas. Please quantify all weather-related damages to
your property and
         operations for each of the periods covered by your Form 10-K.

         We also note that at the time of the filing of your Form 10-K you did
not believe there had
         been any weather-related impacts due to climate change that had
materially impacted the
         cost of insurance. Please quantify your insurance costs for each of
the periods covered by
         your Form 10-K and explain whether changes to your insurance costs are
expected in
         future periods.

         In addition, tell us how you considered including disclosure regarding
the potential impact
         to you from weather-related disruptions to your suppliers.
4.       We note your response to prior comment 8 and reissue it in part.
Please quantify any
         compliance costs related to climate change for each of the periods
covered by your Form
         10-K.
       Please contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any other questions.



FirstName LastNameGerald Laderman                             Sincerely,
Comapany NameUnited Airlines Holdings, Inc.
                                                              Division of
Corporation Finance
October 28, 2022 Page 2                                       Office of Energy
& Transportation
FirstName LastName