SEC Comment Letter for IRON MOUNTAIN INC (IRM) (CIK 0001020569) (IRM) — Jul 24, 2013
IRON MOUNTAIN INC (IRM) (CIK 0001020569)
Date: July 24, 2013 · CIK: 0001020569 · Accession: 0000000000-13-040550
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13045
Referenced dates: July 1, 2013, July 11, 2013
Letter
July 24 , 2013 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, 2012 Filed March 1, 2013 File No. 001-13045
Dear Mr. McKeon :
We have reviewed your letter dated July 11, 2013 , in response to the Staff’s letter dated July 1, 2013 and have t he following additional comment . Please revise your disclosure in response to our comments. Your response should be submitted in electronic form, under the label “corresp” with a copy to the staff. Please respond within ten (10) business days.
Quarterly Report on f orm 10 -Q for the Quarter ended March 31, 2013 Note (9)Discontinued Operations, page 42 Italian Operations
1. We note from your response to our prior comment number 3 that the Company concluded in conjunction with the filing of the Form 10 -Q for the quarter e nded March 31, 2013 that the income before taxes of $2,712 primarily resulting from the involuntary conversion of property, plant and equipment associated with the Italian Operations was not material to its consolidated financial statements and therefore d isclosure of the source of this income before taxes was necessary. As the net of tax amount associated with this involuntary conversion of $2,103 represents in excess of ten percent of your income from continuing operations and net income for the period, w e believe some disclosure as to the nature of this income should be provided in MD&A. Please confirm that you will revise MD&A in future filings to explain the nature of this income from discontinued operations including how the amount was calculated or de termined.
Mr. Brian P. McKeon Iron Mountain Incorporated July 24 , 2013 Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned, at (202) 551 -3750 , if you have questions regarding comments on the financial statements and related matters. Please contact the undersigned with any other ques tions.
Sincerely,
/s/ Linda Cvrkel
Show Raw Text
July 24 , 2013
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, 2012
Filed March 1, 2013
File No. 001-13045
Dear Mr. McKeon :
We have reviewed your letter dated July 11, 2013 , in response to the Staff’s letter dated
July 1, 2013 and have t he following additional comment . Please revise your disclosure in
response to our comments. Your response should be submitted in electronic form, under the label
“corresp” with a copy to the staff. Please respond within ten (10) business days.
Quarterly Report on f orm 10 -Q for the Quarter ended March 31, 2013
Note (9)Discontinued Operations, page 42
Italian Operations
1. We note from your response to our prior comment number 3 that the Company concluded
in conjunction with the filing of the Form 10 -Q for the quarter e nded March 31, 2013 that
the income before taxes of $2,712 primarily resulting from the involuntary conversion of
property, plant and equipment associated with the Italian Operations was not material to
its consolidated financial statements and therefore d isclosure of the source of this income
before taxes was necessary. As the net of tax amount associated with this involuntary
conversion of $2,103 represents in excess of ten percent of your income from continuing
operations and net income for the period, w e believe some disclosure as to the nature of
this income should be provided in MD&A. Please confirm that you will revise MD&A in
future filings to explain the nature of this income from discontinued operations including
how the amount was calculated or de termined.
Mr. Brian P. McKeon
Iron Mountain Incorporated
July 24 , 2013
Page 2
You may contact Effie Simpson at (202) 551 -3346 , or in her absence, the undersigned, at
(202) 551 -3750 , if you have questions regarding comments on the financial statements and
related matters. Please contact the undersigned with any other ques tions.
Sincerely,
/s/ Linda Cvrkel
Linda Cvrkel
Branch Chief