SEC Comment Letter for IRON MOUNTAIN INC (IRM) (CIK 0001020569) (IRM) — May 1, 2012
IRON MOUNTAIN INC (IRM) (CIK 0001020569)
Date: May 1, 2012 · CIK: 0001020569 · Accession: 0000000000-12-022347
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13045
Referenced dates: April 23, 2012
Letter
May 1, 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 response letter dated April 23, 2012 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 10. Commitments and Contingencies, page 130
(h) Government Contract Billing Matter, page 133
1. We note from your response to our prior comment three that should it be determined that an adjustment is necessary in future peri od, you will assess, at that time, whether the adjustment is a result of a change in estim ate or the correction of an error and the accounting and disclosure will be assessed ac cordingly. However, we would like you to revise your future filings to disclose the possibility of a future adjustment and your planned accounting treatment for such an adju stment. Please note th at this disclosure should be included even in periods that do not include an adjust ment to the amounts already recorded as corrections of an error. Please confirm that you will include this disclosure as requested.
Mr. Brian P. McKeon Iron Mountain Incorporated May 1, 2012 Page 2
Note 14. Discontinued Operations Digital Operations, page 136
2. We note from your response to our prior comment four that any change in the estimated amount of working capital will be disclosed in the notes to the financial statements and recorded within Gain(loss) on Sale of Di scontinued Operations, Net of Tax in your statements of operations. However, as prev iously requested, we would like you to revise future filings to disclose how you will account for any changes in the working capital adjustment in your financial statements, whethe r or not there has been any change in that reporting period. Please confirm that you will revise your notes accordingly.
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
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May 1, 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 response letter dated April 23, 2012 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 10. Commitments and Contingencies, page 130 (h) Government Contract Billing Matter, page 133 1. We note from your response to our prior comment three that should it be determined that an adjustment is necessary in future peri od, you will assess, at that time, whether the adjustment is a result of a change in estim ate or the correction of an error and the accounting and disclosure will be assessed ac cordingly. However, we would like you to revise your future filings to disclose the possibility of a future adjustment and your planned accounting treatment for such an adju stment. Please note th at this disclosure should be included even in periods that do not include an adjust ment to the amounts already recorded as corrections of an error. Please confirm that you will include this disclosure as requested. Mr. Brian P. McKeon Iron Mountain Incorporated May 1, 2012 Page 2 Note 14. Discontinued Operations Digital Operations, page 136 2. We note from your response to our prior comment four that any change in the estimated amount of working capital will be disclosed in the notes to the financial statements and recorded within Gain(loss) on Sale of Di scontinued Operations, Net of Tax in your statements of operations. However, as prev iously requested, we would like you to revise future filings to disclose how you will account for any changes in the working capital adjustment in your financial statements, whethe r or not there has been any change in that reporting period. Please confirm that you will revise your notes accordingly. 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