SEC Comment Letter for CROWN CASTLE INC. (CCI) (CIK 0001051470) (CCI) — Jun 17, 2013
CROWN CASTLE INC. (CCI) (CIK 0001051470)
Date: June 17, 2013 · CIK: 0001051470 · Accession: 0000000000-13-032914
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-16441
Referenced dates: April 26, 2013
Letter
June 17, 2013 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 Year Ended December 31, 2012 Filed February 12, 2013 Response dated May 31, 2013 File No. 001-16441
Dear Mr. Brown:
We have reviewed your response letter and have the following comment . As noted in our letter dated April 26, 2013, we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of y our documents. In our comment, we asked you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you wi ll provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment , we may have additional comments .
Form 10 -K for the Year Ended December 31, 2012
Accounting for Acquisitions, page 32
1. We note your response to comment one. Tell us how you considered the guidance in paragraphs 36 and 38(b) of ASC 840 -10-25 in your accounting since the lease involves both land and buildings (i.e. towers) and does not meet the bargain purchase option criterion.
Mr. Jay A. Brown Crown Castle International Corp. June 17, 2013 Page 2
You may contact Kathryn Jacobson , Senior Staff Accountant, at (202) 551 -3365 or Ivette Leon , Assistant Chief Accountant , at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions.
Sincerely,
/s/ Robert S. Littlepage for
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June 17, 2013 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 Year Ended December 31, 2012 Filed February 12, 2013 Response dated May 31, 2013 File No. 001-16441 Dear Mr. Brown: We have reviewed your response letter and have the following comment . As noted in our letter dated April 26, 2013, we have limited our review to only your financial statements and related disclosures and do not intend to expand our review to other portions of y our documents. In our comment, we asked you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advising us when you wi ll provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment , we may have additional comments . Form 10 -K for the Year Ended December 31, 2012 Accounting for Acquisitions, page 32 1. We note your response to comment one. Tell us how you considered the guidance in paragraphs 36 and 38(b) of ASC 840 -10-25 in your accounting since the lease involves both land and buildings (i.e. towers) and does not meet the bargain purchase option criterion. Mr. Jay A. Brown Crown Castle International Corp. June 17, 2013 Page 2 You may contact Kathryn Jacobson , Senior Staff Accountant, at (202) 551 -3365 or Ivette Leon , Assistant Chief Accountant , at (202) 551 -3351 if you have questions regarding comments on the financial statements and related matters. Please contact me at (202) 551 -3810 with any other questions. Sincerely, /s/ Robert S. Littlepage for Larry Spir gel Assistant Director