SEC Comment Letter for DIGITAL REALTY TRUST, INC. (DLR, DLR-PJ, DLR-PK, DLR-PL) (CIK 0001297996) (DLR) — Mar 27, 2012
DIGITAL REALTY TRUST, INC. (DLR, DLR-PJ, DLR-PK, DLR-PL) (CIK 0001297996)
Date: March 27, 2012 · CIK: 0001297996 · Accession: 0000000000-12-015587
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File numbers found in text: 000-54023
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March 27, 2012 Via E-mail Mr. A. William Stein Chief Financial Officer & Chief Investment Officer Digital Realty Trust, Inc. 560 Mission Street, Suite 2900 San Francisco, CA 94105 Re: Digital Realty Trust, Inc. Digital Realty Trust, L.P. Form 10-K for the fiscal ye ar ended Decem ber 31, 2011 Filed February 28, 2012 File Nos. 001- 32336 and 000-54023 Dear Mr. Stein: We have reviewed your filing and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advi sing us when you will provide the requested response. If you do not believe our comments apply to your fact s and circumstances or do not believe an amendment is appropriate, pl ease tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to these comments, we ma y have additional comments. Form 10-K for the Year Ended December 31, 2011 General 1. Please advise us whether management consid ers net operating income and/or same store net operating income as key performance indicat ors. We may have further comments. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. Mr. A. William Stein Digital Realty Trust, Inc. March 27, 2012 Page 2 In responding to our comments, please provi de a written statement from the company acknowledging that: the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States. If you have any questions, you may contact Eric McPhee at (202) 551-3693 or me at (202) 551-3486. Sincerely, /s/ Daniel L. Gordon Daniel L. Gordon Branch Chief