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                                                            January 13, 2025

Eun (Angela) Nam
Chief Financial Officer and Chief Accounting Officer
FTAI Aviation Ltd.
415 West 13th Street, 7th Floor
New York, NY 10014

       Re: FTAI Aviation Ltd.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Response dated January 3, 2025
           File No. 001-37386
Dear Eun (Angela) Nam:

       We have reviewed your January 3, 2025 response to our comment letter and
have the
following comment(s).

       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.
Unless we note otherwise, any references to prior comments are to comments in
our
December 13, 2024 letter.

Form 10-K for Fiscal Year Ended December 31, 2023
Consolidated Financial Statements of FTAI Aviation Ltd.
Consolidated Balance Sheets, page 53

1.     We read your response to prior comment 1. Please present accounts
       payable separately from accrued liabilities. Also, tell us and disclose
with
       quantification as of each balance sheet date any component(s) of other
current assets
       and accrued liabilities exceeding the disclosure threshold. Refer to
Rules 5-02.8, .19
       and .20 of Regulation S-X.
 January 13, 2025
Page 2

       Please contact Blaise Rhodes at 202-551-3774 or Rufus Decker at
202-551-3769 if
you have any questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Trade &
Services
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