SEC Comment Letter for IRON MOUNTAIN INC (IRM) (CIK 0001020569) (IRM) — Sep 7, 2010
IRON MOUNTAIN INC (IRM) (CIK 0001020569)
Date: Sept. 7, 2010 · CIK: 0001020569 · Accession: 0000000000-10-051922
AI Filing Summary & Sentiment
File numbers found in text: 001-13045
Letter
September 7, 2010
Brian P. McKeon Chief Financial Officer Iron Mountain Incorporated 745 Atlantic Avenue Boston, MA 02111 Re: Iron Mountain Incorporated Form 10-K Filed February 26, 2010 File No. 001-13045 Definitive Proxy Statement on Schedule 14A Filed April 23, 2010 Dear Mr. McKeon: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments. Definitive Proxy Statement on Schedule 14A
General
1. We note that you have not provided disclosure regarding compensation committee interlocks and insider participation. Please include the di sclosure required by Item 407(e)(4) in future filings or advise. Other Named Executive Officer s’ Base-Salary, page 39
2. In future filings, please include an exhibit to list the one hundred a nd fifty organizations included in the “Radford Survey Group,” as it appears that you be nchmark against these companies.
Brian P. McKeon Iron Mountain Incorporated September 7, 2010 Page 2
Consideration of Risk in Our Compensation Programs, page 58
3. We note your disclosure in response to Item 402(s) of Regulation S-K. Please describe the process you undertook to reach the conclusion that disclosure is not necessary. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provi de a written statement from the company acknowledging that: • the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of the United States.
Please contact Chanda DeLong at (202) 551- 3490 or me at (202) 551-3412 with any other questions. Sincerely, Amanda Ravitz Branch Chief – Legal
Show Raw Text
September 7, 2010
Brian P. McKeon Chief Financial Officer Iron Mountain Incorporated 745 Atlantic Avenue Boston, MA 02111
Re: Iron Mountain Incorporated Form 10-K
Filed February 26, 2010 File No. 001-13045 Definitive Proxy Statement on Schedule 14A Filed April 23, 2010
Dear Mr. McKeon:
We have reviewed your filing and have the following comments. In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response. If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
Definitive Proxy Statement on Schedule 14A
General
1. We note that you have not provided disclosure regarding compensation committee
interlocks and insider participation. Please include the di sclosure required by Item
407(e)(4) in future filings or advise.
Other Named Executive Officer s’ Base-Salary, page 39
2. In future filings, please include an exhibit to list the one hundred a nd fifty organizations
included in the “Radford Survey Group,” as it appears that you be nchmark against these
companies.
Brian P. McKeon Iron Mountain Incorporated September 7, 2010 Page 2
Consideration of Risk in Our Compensation Programs, page 58
3. We note your disclosure in response to Item 402(s) of Regulation S-K. Please describe
the process you undertook to reach the conclusion that disclosure is not necessary. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
In responding to our comments, please provi de a written statement from the company
acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclo sure 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 federa l securities laws of the United States.
Please contact Chanda DeLong at (202) 551- 3490 or me at (202) 551-3412 with any
other questions.
Sincerely,
Amanda Ravitz Branch Chief – Legal