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SEC Comment Letter for CROWN CASTLE INC. (CCI) (CIK 0001051470) (CCI) — Aug 20, 2012

CROWN CASTLE INC. (CCI) (CIK 0001051470)
Date: Aug. 20, 2012 · CIK: 0001051470 · Accession: 0000000000-12-045037

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
August 20, 2012
Author
/s/ Robert S. Littlepage for
Form
UPLOAD
Company
CROWN CASTLE INC. (CCI) (CIK 0001051470)

Letter

August 20, 2012 Via E -mail Mr. Jay A. Brown Chief Financial Officer Crown Castle International Corp. 1220 Augusta Drive, Suite 500 Houston, Texas 77057 -2261

Re: Crown Castle International Corp. Form 10 -K for the Fiscal Year Ended December 31, 2011 Filed February 13, 2012 File No. 001 -16441

Dear Mr. Brown:

We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us wi th information so we may better understand your disclosure.

Please respond to this letter within ten business days and indicate that you will comply with our comments in future filings. Confirm in writing that you will do so and also explain to us how you intend to comply. If you do not believe our comments apply to your facts and circumstances or do not believe compliance in future disclosure is appropriate, please tell us why in your response.

After reviewing the information you provide in respons e to these comments, we may have additional comments. Form 10 -K for the Year Ended December 31, 2011 A substantial portion of our revenues is derived from a small number of customers …, page 8 1. We note that you derive 21% of your revenues from Sprint Nextel . Per your disclosure, the elimination of Sprint’s push -to-talk network referred to as iDEN and deployment of Network Vision “will likely result in Sprint not renewing certain contracts” with you. Please disclose in your MD&A how the non -renewal will imp act your operations and cash flows in 2012 and subsequent periods.

Mr. Jay A. Brown Crown Castle International Corp . August 20, 2012 Page 2

Contractual Cash Obligations, page 27 2. We note in footnote (c) that the impact of principal payments that will commence following the anticipated repayment dates of your tower revenue n otes on 2015, 2017 and 2020 are not considered. Please revise to quantify in the footnote the principal amounts having anticipated repayment dates in 2015, 2017 and 2020 and the related interest included in the “Thereafter” column. If true, disclose that you do not expect to repay such notes in full on or prior to their respective anticipated repayment dates. We note your disclosure in footnote (d) of Note 6 on page 53. We urge all persons who are responsible for the accuracy and adequacy of the disclosu re 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 disclosu re, 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 o f 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.

You may contact Kathryn Jacobson, Senior Accountant, at (202) 551 -3365 or Dean Suehiro, Senior Accountant, at (202) 551 -3384 if you have questions regarding comments on the financial statements and related matters. Please contact Paul Fischer, Attorney -Advisor, at (202) 551-3415, Jessica Plowgian, Attorney -Advisor at (202) 551 -3367, or me at (202) 551 -3810 with any other questions.

Sincerely,
/s/ Robert S. Littlepage for

Show Raw Text
August 20, 2012

Via E -mail
Mr. Jay A. Brown
Chief Financial Officer
Crown Castle International Corp.
1220 Augusta Drive, Suite 500
Houston, Texas 77057 -2261

Re: Crown Castle International Corp.
Form 10 -K for the Fiscal Year Ended December 31, 2011
Filed February 13, 2012
 File No. 001 -16441

Dear Mr. Brown:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us wi th information so we may better understand your
disclosure.

Please respond to this letter within ten business days and indicate that you will comply
with our comments in future filings.   Confirm in writing that you will do so and also explain to
us how you intend to comply.  If you do not believe our comments apply to your facts and
circumstances or do not believe compliance in future disclosure is appropriate, please tell us why
in your response.

  After reviewing the information you provide in respons e to these comments, we may
have additional comments.
Form 10 -K for the Year Ended December 31, 2011
A substantial portion of our revenues is derived from a small number of customers …, page 8
1. We note that you derive 21% of your revenues from Sprint Nextel .  Per your disclosure, the
elimination of Sprint’s push -to-talk network referred to as iDEN and deployment of Network
Vision “will likely result in Sprint not renewing certain contracts” with you.  Please disclose
in your MD&A how the non -renewal will imp act your operations and cash flows in 2012 and
subsequent periods.

Mr. Jay A. Brown
Crown Castle International Corp .
August 20, 2012
Page 2

 Contractual Cash Obligations, page 27
2. We note in footnote (c) that the impact of principal payments that will commence following
the anticipated repayment dates of your tower revenue n otes on 2015, 2017 and 2020 are not
considered.  Please revise to quantify in the footnote the principal amounts having anticipated
repayment dates in 2015, 2017 and 2020 and the related interest included in the “Thereafter”
column.  If true, disclose that  you do not expect to repay such notes in full on or prior to their
respective anticipated repayment dates.  We note your disclosure in footnote (d) of Note 6 on
page 53.
We urge all persons who are responsible for the accuracy and adequacy of the disclosu re
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 disclosu re, 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 o f 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.

You may contact Kathryn Jacobson, Senior Accountant, at (202) 551 -3365 or Dean
Suehiro,  Senior Accountant, at (202) 551 -3384 if you have questions regarding comments on the
financial statements and related matters.  Please contact Paul Fischer,  Attorney -Advisor, at (202)
551-3415, Jessica Plowgian, Attorney -Advisor at (202) 551 -3367, or me at (202) 551 -3810 with
any other questions.

        Sincerely,

        /s/ Robert S. Littlepage  for

        Larry Spirgel
        Assistant Director