SecProbe.io

March 31 , 2014

Via E-Mail
Mr. Roderick Day
Chief Financial Officer
Iron Mountain, Inc .
One Federal Street
Boston, MA 02110

Re: Iron Mountain, Inc .
 Form 10-K for the Year Ended December 31, 2013
Filed February 28 , 2014
 File No. 1 -13045

Dear  Mr. Day:

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 advising 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, please tell us why in your response.

After reviewing the information you provide in response to these  comments, we may
have additional comments.

Note 2. Summary of Significant Accountin g Policies
(g) Goodwill and Other Intangible Assets, page 82

1. We note from the disclosure in footnote (1) to the table reflecting changes in your
goodwill balance during the various periods presented in your financial statements that
fair value and other a djustments made to goodwill in the amount of $8,522 during 2013
include $8,446 in net adjustments to property, plant and equipment, net customer
relationships and deferred taxes as well as $76 of cash paid related to acquisitions made
in previous years. Pl ease tell us and revise the notes to your financial statements to
explain in further detail the nature and timing of the changes in facts and circumstances,
or new information received, that resulted in these fair value adjustments to goodwill
during 2013.  Your response should also indicate the date that these prior year acquisitions
occurred and should explain why these adjustments to the fair values of the net assets
acquired did not occur until 2013.

Mr. Roderick Day
Iron Mountain, Inc.
March  31, 2014
Page 2

 Note 5. Selected Consolidated Financial Statements of Parent, Guarantors, Canada Company and
Non-Guarantors, page 106

2. We note from the disclosure in the last paragraph on page 107 that in July 2013, certain
of Canada Company’s operating subsidiaries (the “Amalgamated Entities”), were
amalgamated into Canada Company and as part of your proposed conversion to a real
estate investment trust, Canada Company contributed certain assets and liabilities into
two newly -formed wholly owned entities (the “Canadian Subsidiaries”). We also note
that the assets, liabilitie s, equity , results of operations and cash flows of the Amalgamated
Entities, previously presented within the Non -Guarantors column, are now presented
within the Canada Company column. We further note that the assets, liabilities, equity,
results of operatio ns and cash flows of the Canadian Subsidiaries, previously presented
within the Canada Company column, are now presented within the Non -Guarantors
column. Please tell us and revise the notes to your financial statements to explain how the
July 2013 transac tions and the related revisions made to the condensed consolidating
information for the parent guarantors, Canada company and the non -guarantors, impacted
the amounts presented for Canada Company and non -Guarantors in 2011 and 2012.

We urge all persons wh o are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require .  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 connection with responding to our comments, please p rovide, in writing, a statement
from the company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure 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 federal securities laws of the United States.

Mr. Roderick Day
Iron Mountain, Inc.
March  31, 2014
Page 3

 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 questions.

Sincerely,

        /s/ Linda Cvrkel

Linda Cvrkel
Branch Chief