SecProbe.io

Mail Stop 3233
September 10, 2015

Via E -mail
Ernest Cloutier
General Counsel & Secretary
Iron Mountain Incorporated
One Federal Street
Boston, MA 02110

Re: Iron Mountain Incorporated
 Preliminary Proxy Statement on Schedule 14A
Filed August 25, 2015
File No. 001 -13045

Dear Mr. Cloutier :

We have limited our review of your filing to those issues we have addressed in our
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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

General

1. We note your disclosure on page 87 that the st ock to be issued in the Transaction will be
issued pursuant to an exemption from the registration requirements provided by Section
3(a)(10) of the Securities Act.  Please provide us with a detailed factual and legal analysis
setting forth why you believe y ou may properly rely on this exemption.  Refer to Division
of Corporation Finance Staff Legal Bulletin No. 3A (June 18, 2008).

2. Please advise us of your consideration of the position expressed in SEC Release 34 -
14699 (April 24, 1978)  and the relevant no -action positions involving cash option
mergers with similar cash/stock election  features.   In this regard, please revise to clarify
the timing of when Recall shareholders make their election  relative to the time that they
vote on the Transaction, and supplem entally address how the structure of your  cash
election compares to prior no -action letters issued by the staff involving similar
circumstances.   See e.g., Entergy Corporation (November 13, 1992).

Ernest Cloutier
Iron Mountain Incorporated
September 10, 2015
Page 2

 3. Please revise to include the audited financial statements for Recall as required by Item
14(c)(2) of Schedule 14A, or advise us.

We urge all persons who 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 Ac t 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 responding to our comments, please provide  a written 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 Uni ted States.

Please contact Rahul Patel  at (202) 551 -3799  or me at (202) 551 -7262  with any other
questions.

Sincerely,

 /s/ Peggy Kim

 Peggy Kim
Senior Counsel
Office of Real Estate and
Commodities

cc: Michael Aiello, Esq .
 Weil, Gotshal & Manges  LLP