SecProbe.io

April 10, 2012
 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, 2011
Filed February 28, 2012 File No. 001-13045

Dear 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 10 bus iness days by confirming that you will revise
your document in future filing and providing an y requested information.  If you do not believe
our comments apply to your facts and circumst ances, please tell us why in your response.
 After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10-K for the Year Ended December 31, 2011

 Note 7. Income Taxes, page 120

1. We note your disclosure that you have not  recorded deferred taxes on book over tax
outside basis differences related to certai n foreign subsidiaries because such basis
differences are not expected to reverse in th e foreseeable future and you intend to reinvest
indefinitely outside the U.S.   Please revise the notes to the financial statements to
disclose the amount of undist ributed earnings of your foreig n subsidiaries as required by
ASC 740-30-50.
 Note 8. Quarterly Results of Op erations (Unaudited), page 125

2. Please revise to discuss the nature of any unus ual or infrequent items that impacted your
quarterly results of operations for the various periods  presented, such as the sale of the
Digital Business in the sec ond quarter of 2011, and the impairment of your Western

Mr. Brian P. McKeon Iron Mountain Incorporated April 10, 2012 Page 2

 Europe’s reporting unit goodwill in the third quarter of 2011. Refer to the requirement
outlined in Item 302(a)(3) of Regulation S-K.
 Note 10. Commitments and Contingencies, page 130

 (h) Government Contract Billing Matter, page 133

3. We note your disclosure that  in June 2011 you voluntarily di sclosed the potential non-
compliance in your government contract billi ng to the GSA and OIG and you continue to
review this matter and will provide GSA and OIG with the proposed pricing adjustment
to be refunded.  In light of th e fact that it appears that this  matter has not been settled and
you disclose that GSA and OIG may not agre e with your determination of the refund
amount, please explain to us how you determined the amounts to be recorded as corrections of an error in the statements of operations for the years ended December 31,
2010 and 2009 as disclosed in Note 2(y).  As part of your response,  please tell us and
disclose in Note 2(y) in future filin gs, how you will account for any additional
adjustments that may result from th e discussions with GSA and OIG.
 Note 14. Discontinued Operations Digital Operations, page 136

4. We note your disclosure that you and Aut onomy are in disagreement regarding the
working capital adjustment in the Digital Sale Agreement.  Please tell us and disclose in
the notes to the financial statements how you will account for any changes in the working
capital adjustment in your financial statements.

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 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.

Mr. Brian P. McKeon Iron Mountain Incorporated April 10, 2012 Page 3

 You may contact Claire Erla nger at (202) 551-3301 if you have questions regarding
comments on the financial statements and related matters.  You may also contact me at (202)
551-3813.
Sincerely,
   /s/ Linda Cvrkel    Linda Cvrkel
Branch Chief