United States securities and exchange commission logo October 10, 2023 Eun (Angela) Nam Chief Financial Officer and Chief Accounting Officer FTAI Aviation Ltd. 1345 Avenue of the Americas, 45th Floor New York, NY 10105 Re: FTAI Aviation Ltd. Form 10-K for Fiscal Year Ended December 31, 2022 File No. 001-37386 Dear Eun (Angela) Nam: 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. Sincerely, Division of Corporation Finance Office of Trade & Services