SEC Comment Letter 0000000000-24-006945 to DIGITAL REALTY TRUST, INC. (DLR)
DIGITAL REALTY TRUST, INC.
Date: June 17, 2024 · CIK: 0001297996 · Accession: 0000000000-24-006945
AI Filing Summary & Sentiment
File numbers found in text: 001-32336
Letter
United States securities and exchange commission logo June 17, 2024 Andrew Power President & Chief Executive Officer Digital Realty Trust, Inc. 5707 Southwest Parkway, Building 1, Suite 275 Austin, TX 78735 Re:Digital Realty Trust, Inc. Form 10-K for the year ended December 31, 2023 Form 8-K filed May 2, 2024 File No. 001-32336 Dear Andrew Power: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Form 8-K filed May 2, 2024 Exhibit No. 99.1 Definitions, page 31 1.We note that your measures Core FFO and Adjusted EBITDA contain adjustments for other non-core items. Please tell us what types of revenues or expenses are being added back, and to the extent that these are significant to the non-GAAP measure in future filings, please provide further explanation within your disclosure. In closing, 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. Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468 with any questions.
FirstName LastNameAndrew Power Comapany NameDigital Realty Trust, Inc. June 17, 2024 Page 2 FirstName LastName Andrew Power Digital Realty Trust, Inc. June 17, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
June 17, 2024
Andrew Power
President & Chief Executive Officer
Digital Realty Trust, Inc.
5707 Southwest Parkway, Building 1, Suite 275
Austin, TX 78735
Re:Digital Realty Trust, Inc.
Form 10-K for the year ended December 31, 2023
Form 8-K filed May 2, 2024
File No. 001-32336
Dear Andrew Power:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments.
Form 8-K filed May 2, 2024
Exhibit No. 99.1
Definitions, page 31
1.We note that your measures Core FFO and Adjusted EBITDA contain adjustments for
other non-core items. Please tell us what types of revenues or expenses are being added
back, and to the extent that these are significant to the non-GAAP measure in future
filings, please provide further explanation within your disclosure.
In closing, 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.
Please contact Eric McPhee at 202-551-3693 or Wilson Lee at 202-551-3468 with any
questions.
FirstName LastNameAndrew Power
Comapany NameDigital Realty Trust, Inc.
June 17, 2024 Page 2
FirstName LastName
Andrew Power
Digital Realty Trust, Inc.
June 17, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction