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SEC Comment Letter for CROWN CASTLE INC. (CCI) (CIK 0001051470) (CCI) — May 3, 2017

CROWN CASTLE INC. (CCI) (CIK 0001051470)
Date: May 3, 2017 · CIK: 0001051470 · Accession: 0000000000-17-015547

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Date
December 31, 2016
Author
/s/ Eric McPhee
Form
UPLOAD
Company
CROWN CASTLE INC. (CCI) (CIK 0001051470)

Letter

Mail Stop 3233 May 3, 201 7 Via E -mail Mr. Daniel K. Schlanger Chief Financial Officer Crown Castle International Corp. 1220 Augusta Drive, Suite 600 Houston , TX 77057 -2261

Re: Crown Castle International Corp. Form 10-K for the fiscal year ended December 31, 2016 Filed February 22, 201 7 Form 8-K dated January 25, 2017 Filed January 25, 2017 File No. 1-16441

Dear Mr. Schlanger :

We have reviewed your filing s and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure.

Please respond to our comment 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 comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to our comment, we may have addit ional comments.

Form 8 -K filed January 25, 2017

Exhibit 99.1

1. We note your presentation of the measure site rental gross margin. As this measure appears to be a non -GAAP measure, in future filings please provide the disclosures required by Item 10(e)(1)(i) of Regulation S -K.

We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Daniel K. Schlanger Crown Castle International Corp. May 3, 2017 Page 2

You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 - 3693 with any questions.

Sincerely,
/s/ Eric McPhee

Show Raw Text
Mail Stop 3233

May 3, 201 7

Via E -mail
Mr. Daniel K. Schlanger
Chief Financial Officer
Crown Castle International Corp.
1220 Augusta  Drive, Suite 600
Houston , TX  77057 -2261

Re:  Crown Castle International Corp.
 Form 10-K for the  fiscal  year ended December  31, 2016
Filed February  22, 201 7
Form 8-K dated January  25, 2017
Filed January 25, 2017
File No. 1-16441

Dear Mr. Schlanger :

We have reviewed your filing s and have the following comment.  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to our comment  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
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to our comment, we may have  addit ional comments.

Form 8 -K filed January 25, 2017

Exhibit 99.1

1. We note your presentation of the measure site rental gross margin. As this measure
appears to be a non -GAAP measure, in future filings please provide the disclosures
required by Item 10(e)(1)(i) of Regulation S -K.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Daniel  K. Schlanger
 Crown Castle International Corp.
 May 3, 2017
 Page 2

 You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 -
3693 with any questions.

Sincerely,

        /s/ Eric McPhee

Eric McPhee
Senior Staf f  Accountant
Office of Real Estate & -
    Commodities