SecProbe.io

June 20, 2011
 Via E- Mail

 Mr. Brian P. McKeon Chief Financial Officer Iron Mountain Incorporated 745 Atlantic Avenue Boston, Massachusetts 02111

Re: Iron Mountain Incorporated
 Form 10-K for the year ended December 31, 2010
Filed March 1, 2011
 File No. 1-13045

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.

Mr. Brian P. McKeon Iron Mountain Incorporated June 20, 2011 Page 2

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Non-GAAP Measures
Free Cash Flows before Acquisitions and Disc retionary Investments, or FCF, page 35

1. We note your disclosure regard ing the fact that you believe free cash flow (FCF) is a
useful measure for investors in determining your  ability to generate excess cash flows for
reinvestment in the business, for discretiona ry deployment in investments such as real
estate or acquisition opportunitie s, the potential returning of capital to shareholders or the
repayment of indebtedness.  As the repayment of indebtedness is mentioned after the discretionary expenditures, as well as the fact that FCF excludes other mandatory
expenditures such as debt service, this st atement appears to imply that the measure
represents the residual cash flow available for discretionary pur poses, or rather non-
mandatory repayment of indebtedness.  Please te ll us and revise your disclosure in future
filings to clarify whether manda tory debt service requirement s or other non-discretionary
expenditures are deducted from the measure.   Please refer to Question 102.07 of the
Compliance and Disclosure Interpretations issues on January 11, 2010 for further details.
 Note 10.  Commitments and Contingencies

c.  Litigation, page 119

2. We note in several instances where you i ndicate that even though you are unable to
predict the final outcome of the case, you do not expect that it will have a material impact
on the financial statements.  We do not cons ider such disclosure s to be adequate.
Pursuant to ASC 450-20-50-3 if  no accrual is made for a loss contingency because one or
both of the conditions are not met, or an e xposure to loss exists in excess of the amount
accrued pursuant to the provisions of ASC 450-20-30-1, disclosure of the contingency
shall be made when there is at least a reas onable possibility that a loss or an additional
loss may have been incurred.  The disclosure shall indicate the nature of the contingency
and shall give an estimate of the possible lo ss or range of loss or state that such an
estimate cannot be made.  For contingencies where an estimate cannot be made of the
possible loss or range of loss, please advise us as to why.  We may have further comment
upon receipt of your response.
 e.  Chile Eathquake, page 120

3. We note that with respect to the Februa ry 27, 2010 earthquake in Chile, you have
recorded gains on the disposal/w rite-down of property, plant and equipment, net in your
statement of operations of approximately $10,200 for the year ended December 31, 2010,
and have received approximately $27,000 in  insurance recoveries.  Such amount
represents a portion of your business pe rsonal property, business interruption, and
expense claims filed with your insurance carrier s.  Please tell us and revise the notes to
your consolidated financial statements in futu re filings to disclose your accounting policy
for involuntary conversions of property plan t and equity and proceeds from business
interruption insurance.  Your  response and revised policy should address the timing for

Mr. Brian P. McKeon Iron Mountain Incorporated June 20, 2011 Page 3

 when such proceeds are recognized within th e financial statements, and the aggregate
amount of business interrupti on insurance recoveries rec ognized during the period and
line item(s) in the statements of operations in  which those recoveries  are classified.
 Form 10-Q for the period ended March 31, 2011

4. We note that in January 2011, you acquired th e remaining 80% interest of your joint
venture in Poland in a stock transaction fo r an estimated purchase price of $69,500.  We
also note that your calculation of the fair valu e of your previously held  equity interest of
$10,425 utilized an estimate of the control pr emium paid which reduced the total fair
value of the consideration for the purchase of the remaining 80%  interest by 40%.  In this
regard, please advise us and revise future filings tell us how you determined that 40% was an appropriate discount factor for the control premium. You response should include
significant assumptions used and/or factors considered by management in determining
the discount rate.
 Other

5. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the fili ng includes all information required under the
Securities 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 a compa ny’s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

In connection with responding to our comment s, please provide, in writing, a statement
from the company acknowledging that:
 the company is responsible for the adequacy an d 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.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the sta ff of the Division of Corporati on Finance in our review of your
filing or in response to our comments on your filing.

You may contact Effie Simpson at (202) 551-3346, or in her ab sence, Jean Yu, at (202)
551-3305, if you have questions regarding comment s on the financial statements and related
matters.  Please contact the undersigned w ith any other questi ons at (202) 551-3813.

Mr. Brian P. McKeon Iron Mountain Incorporated June 20, 2011 Page 4

Sincerely,

 /s/ Linda Cvrkel
Linda Cvrkel Branch Chief