SEC Comment Letter for IRON MOUNTAIN INC (IRM) (CIK 0001020569) (IRM) — Sep 24, 2015
IRON MOUNTAIN INC (IRM) (CIK 0001020569)
Date: Sept. 24, 2015 · CIK: 0001020569 · Accession: 0000000000-15-047105
AI Filing Summary & Sentiment
Reasoning
Referenced dates: September 10, 2015
Letter
Mail Stop 3233 September 24 , 2015 Via E -mail Ernest Cloutier General Counsel & Secretary Iron Mountain Incorporated One Federal Street Boston, MA 02110
Re: Iron Mountain Incorporated Revised Preliminary Proxy Statement on Schedule 14A Filed September 18 , 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. Please respond to our outstanding comments on your Form 10 -K for the fiscal ye ar ended December 31, 2014 and your Form 10 -Q for the quarterly period ended June 30, 2015, or advise u s as to when you will respond.
2. We note your response to comment two in our letter dated September 10, 2015, and your amended disclosure on page 117. Pl ease revise your disclosure to clarify the timing of when Recall shareholders will receive the Cash Election Form and Scheme Booklet, when Recall shareholders will vote on the Transaction, and when Recall shareholders must return the completed Cash Electio n Form.
Ernest Cloutier Iron Mountain Incorporated September 24 , 2015 Page 2
Please contact Rahul Patel at (202) 551 -3799 or me at (202) 551 -7262 with any other questions.
Sincerely,
/s/ Peggy Kim
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Mail Stop 3233 September 24 , 2015 Via E -mail Ernest Cloutier General Counsel & Secretary Iron Mountain Incorporated One Federal Street Boston, MA 02110 Re: Iron Mountain Incorporated Revised Preliminary Proxy Statement on Schedule 14A Filed September 18 , 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. Please respond to our outstanding comments on your Form 10 -K for the fiscal ye ar ended December 31, 2014 and your Form 10 -Q for the quarterly period ended June 30, 2015, or advise u s as to when you will respond. 2. We note your response to comment two in our letter dated September 10, 2015, and your amended disclosure on page 117. Pl ease revise your disclosure to clarify the timing of when Recall shareholders will receive the Cash Election Form and Scheme Booklet, when Recall shareholders will vote on the Transaction, and when Recall shareholders must return the completed Cash Electio n Form. Ernest Cloutier Iron Mountain Incorporated September 24 , 2015 Page 2 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