SEC Comment Letter 0000000000-23-002236 to AMERICAN TOWER CORP /MA/ (AMT) (CIK 0001053507) (AMT)
AMERICAN TOWER CORP /MA/ (AMT) (CIK 0001053507)
Date: March 7, 2023 · CIK: 0001053507 · Accession: 0000000000-23-002236
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File numbers found in text: 001-14195
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United States securities and exchange commission logo
March 7, 2023
Rodney M. Smith
Chief Financial Officer
American Tower Corporation
116 Huntington Avenue
Boston, MA 02116
Re:American Tower Corporation
Form 10-K for the year ended December 31, 2022
Filed February 23, 2023
File No. 001-14195
Dear Rodney M. Smith:
We have reviewed your filing 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 this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Form 10-K for the year ended December 31, 2022
Notes to Consolidated Financial Statements
11. Fair Value Measurements
Items Measured at Fair Value on a Nonrecurring Basis, page F-38
1.We note you calculated the fair value for certain long-lived assets utilizing projected
future discounted cash flows. Please tell us how you determined it was not necessary to
provide quantitative information about the significant unobservable inputs used in the fair
value measurement of these assets. Please refer to ASC 820-10-50-2(bbb).
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.
You may contact Paul Cline at 202-551-3851 or Jennifer Monick at 202-551-3295 if you
have questions regarding our comment.
FirstName LastNameRodney M. Smith
Comapany NameAmerican Tower Corporation
March 7, 2023 Page 2
FirstName LastName
Rodney M. Smith
American Tower Corporation
March 7, 2023
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction