UNRESOLVED STAFF COMMENTS
−Removed: Delta Air Lines, Inc.
−Removed: | 2024 Form 10-K
CYBERSECURITY
−Removed: CYBERSECURITY
We are committed to safeguarding our information and information systems from unauthorized access, use, disclosure, disruption, modification or destruction.
6 unchanged sentences
Our information technology teams are trained to remediate vulnerabilities identified within established timeframes and our information security team reports to management on a weekly basis regarding the security risk posture of our information technology assets.
−Removed: We have established a dedicated Information Technology Risk team tasked with the goal of ensuring that risk remediation activities are carried out consistently and that risk remediation controls are operating as intended and within established thresholds.
+Added: We have established a dedicated Information Technology Risk team tasked with the goal of ensuring that risk remediation activities are carried out consistently and that risk remediation controls are operating as intended.
Enterprise-wide training is a vital component to reducing risk and protecting customers, employees and company information.
21 unchanged sentences
The Audit Committee receives updates on cybersecurity risks and the security and operations of our information technology systems from our Chief Information Officer and our Chief Information Security Officer at least twice per year with additional updates as requested by the Chair of the Audit Committee.
−Removed: In 2024, the Audit Committee received updates on information security matters at two of its regular meetings.
−Removed: In addition, our Chief Information Officer, our Chief Information Security Officer, other members of our information technology leadership team provided a general overview of information technology matters, including cybersecurity, in a special session with all members of our Board of Directors.
−Removed: In addition to information provided in these meetings, members of our Board also have access to internal and external education on cybersecurity risks.
+Added: In 2025, the Audit Committee received updates on information security matters at all of its regular meetings.
+Added: In addition to information provided in these meetings, all members of our Board also have access to internal and external education on cybersecurity risks.
The Board also benefits from the expertise of one of our members who has significant experience in management of cybersecurity companies.
6 unchanged sentences
In addition, our Chief Information Officer is a member of the Delta Leadership Committee and provides updates to this group as needed about cybersecurity matters.
−Removed: Our cybersecurity incident response plan includes processes for communication about cybersecurity incidents to appropriate levels of management, including to the Risk Council and Leadership Committee, as well as the Audit Committee and the Board, as merited.
+Added: Our cybersecurity incident response plan includes processes for communication about cybersecurity incidents to appropriate levels of management, including to the Delta Risk Council and Delta Leadership Committee, as well as the Audit Committee and the Board, as merited.
Delta Air Lines, Inc.
36 unchanged sentences
Total 24 157 11 133 325
−Removed: (1) We own 195 and have operating leases for two of these regional aircraft.
+Added: (1) We own 202 and have operating leases for three of these regional aircraft.
The remainder are owned or leased by SkyWest Airlines, Inc.
or Republic Airways, Inc.
−Removed: (2) Excluded from the total operating count above are nine CRJ-700 and one CRJ-900 which are owned and temporarily parked as of December 31, 2024.
(2) Endeavor Air, Inc.
3 unchanged sentences
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.