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Iron Mountain Incorporated

745 Atlantic Avenue

Boston, Massachusetts 02111

September 21, 2010

Via EDGAR
and Fax (703) 813-6967

Amanda Ravitz

Branch Chief - Legal

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

RE:            Iron
Mountain Incorporated (the “Company”)

Form 10-K for the year ended December 31,
2009 (the “Form 10-K”)

Filed February 26, 2010

File No. 001-13045

Definitive Proxy Statement on Schedule 14A

Filed April 23, 2010 (the “Proxy Statement” and,
together with the Form 10-K, the “Filings”)

Dear Ms. Ravitz:

The purpose of this letter is to respond to your
letter of September 7, 2010.  For
your convenience, the original staff comments have been repeated in bold
typeface, followed by our responses.

Definitive Proxy Statement on
Schedule 14A

General

1.                                      We note that you have not provided disclosure regarding
compensation committee interlocks and insider participation.  Please include the disclosure required by
Item 407(e)(4) in future filings or advise.

RESPONSE:

1.                                       We have not provided the disclosure required by Item 407(e)(4) based
on the staff’s policy set forth in Regulation S-K Compliance and Disclosure
Interpretation 233.02, that if the only disclosure that a registrant is
required to provide pursuant to Item 407(e)(4) is the identity of the
members of the compensation committee, because the registrant has no
transactions or relationships that trigger a disclosure obligation, the
registrant may omit the Item 407(e)(4) caption.  None of the relationships or transactions
identified in Item 407(e)(4) exists among the members of the Company’s
compensation committee or executive officers of the Company.  In response to the staff’s comment, we will
provide an affirmative statement to this effect in future filings.

Other Named Executive Officers’
Base-Salary page 39

2.                                      In future filings, please include an exhibit to list
the one hundred and fifty organizations included in the “Radford Survey Group,”
as it appears that you benchmark against these companies.

RESPONSE:

2.                                       In response to the staff’s comment, we will identify the one hundred and
fifty organizations included in the “Radford
Survey Group” in future filings if we use that group to benchmark material
elements of a Named Executive Officer’s compensation.

Consideration of Risk in Our
Compensation Programs, page 58

3.                                      We note your disclosure in response to Item 402(s) of
Regulation S-K.  Please describe the
process you undertook to reach the conclusion that disclosure is not necessary.

RESPONSE:

3.                                       As stated on page 58 of the Proxy
Statement, the Compensation Committee concluded that the components and
structure of the Company’s compensation plans do not create risks that are
reasonably likely to result in a material adverse effect on the Company.  The process undertaken to reach this
conclusion involved an analysis of the Company’s compensation plans by
management and the Compensation Committee.

As stated on page 16
of the Proxy Statement, the committee of the Board assigned responsibility for
an area of risk receives reports from the Company executives accountable for
understanding and mitigating the identified risk.  The committee of the Board assigned
responsibility for the risk area then assesses the executive report and
independently considers the severity of the risk and mitigating factors.

In the case of compensation
risk the Compensation Committee received management’s analysis of the risks
that may exist in the Company’s compensation plans and the factors that
mitigate against the plans creating material risks to the Company.  The management team’s analysis was conducted by senior personnel within the human resources and legal
departments, including personnel who focus on compensation.

The management assessment focused on the material
elements of the Company’s compensation plans for all employees, including (i) the
components of compensation which are materially similar to the components of
compensation offered to the Company’s Named Executive Officers discussed on pages 37-38
of the Proxy Statement,  (ii) specific
performance measures used for employees and (iii) the mix between long and
short-term compensation, as well as factors in the Company’s programs that
mitigate

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against potential risks.   Management’s
analysis noted that factors such as individual employee incentive compensation
amount maximums, aligning individual performance targets with Company-wide
performance, setting reasonably attainable goals for all employees, the
internal processes for calculating and reviewing bonus payouts and having a
combination of long-term and short-term incentive payouts, mitigated against
excessive risk taking to achieve goals tied to compensation.

In the Compensation
Committee’s review of the Company’s compensation plans, the committee
considered the management team’s assessment of the various elements of the
Company’s compensation program and factors that mitigate against unreasonable
risk taking.  The Committee then
conducted its own assessment through a discussion of the potential risks and
the factors that mitigate against risk.
The Compensation Committee concluded, based on a combination of factors
including the structure and components of the plans, that the Company’s
compensation plans do not create risks that are reasonably likely to result in
a material adverse effect on the Company.

***********************************************************************

In connection with our responses above, we acknowledge
that:

·                  the Company is responsible for the adequacy and accuracy of the
disclosure in the Filings;

·                  staff comments or changes to disclosure in response to staff comments do
not foreclose the Commission from taking any action with respect to the Filings;
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.

If you have any questions concerning the content of
this letter, please do not hesitate to contact me at (617) 535-2767.

  Sincerely,

  IRON MOUNTAIN INCORPORATED

  By:

  /s/
  Brian P. McKeon

  Brian P. McKeon

  Executive Vice President and Chief Financial Officer

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