United States securities and exchange commission logo April 14, 2023 Kenneth Dichter Chief Executive Officer Wheels Up Experience Inc. 601 West 26th Street, Suite 900 New York, New York 10001 Re: Wheels Up Experience Inc. Form 8-K/A filed March 31, 2023 File No. 001-39541 Dear Kenneth Dichter: 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 Energy & Transportation