UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE


Mail Stop 5546
								December 14, 2005

Via Facsimile and U.S. Mail

Alejandro de la Fuente Goic
Chief Financial Officer
Presidente Riesco 5711 Piso 20
Las Condes,
Santiago, Chile

	Re:	Lan Airlines SA
		Form 20-F for the Fiscal Year Ended December 31, 2004
      Filed September June 30, 2005
		File No. 001-14728

Dear Mr. de la Fuente Goic:

      We have limited our review of the above filing to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
the filing.  Our review with respect to this issue does not
preclude
further review by the Assistant Director group with respect to
other
issues.  At this juncture, we are asking you to provide us with
supplemental information so that we may better understand your
disclosure.  Please be as detailed as necessary in the explanation
you provide for these comments.  After reviewing this information,
we
may raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note from page 20 that your network includes destinations in
Cuba.  We also note that your website provides information for an
office and call center in Cuba.  In light of the fact that Cuba is
identified as a state sponsor of terrorism by the U.S. State
Department and subject to economic sanctions administered by the
U.S.
Treasury Department`s Office of Foreign Assets Control, please
address the materiality of any operations in, and contacts with,
Cuba, such as flights to and from Cuba, Cuban offices and
transactions or arrangements with Cuban entities and nationals.
Discuss whether such operations, transactions, arrangements and
other
contacts constitute a material investment risk for your security
holders.

2. In preparing your response please address materiality in
quantitative terms, including the approximate dollar amount of
revenues and assets associated with Cuban flights and other Cuban
contacts.  Your response should also address materiality in terms
of
qualitative factors that a reasonable investor would deem
important
in making an investment decision, including the potential impact
of
corporate activities upon a company`s reputation and share value.
Among factors that you may deem relevant to your materiality
analysis, we note that Arizona and Louisiana have adopted
legislation
requiring their state retirement systems to prepare reports
regarding
state pension fund assets invested in, and/or permitting
divestment
of state pension fund assets from, companies that do business with
U.S.-designated state sponsors of terrorism.  We also note that
Florida requires issuers to disclose in their prospectuses any
business contacts with Cuba or persons located in Cuba.



      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please
understand
that we may have additional comments after reviewing your
responses
to our comments.  Please file your response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filing; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.





      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Max Webb
		Assistant Director
		Division of Corporation Finance
Alejandro de la Fuente Goic
Lan Airlines
December 14, 2005
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