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CORRESP

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January 7, 2020

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Milan

 Office of Mergers & Acquisitions

Division of Corporation Finance

 U.S. Securities &
Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

 Attention: Perry J. Hindin, Special Counsel

Re:
 Digital Realty Trust, Inc.

Registration Statement on Form S-4

Filed December 6, 2019

File No.: 333-235380

 Dear
Mr. Hindin:

 We are counsel to Digital Realty Trust, Inc. (“DLR” or the “Company”) and on behalf of
DLR, we submit this letter in response to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by letter dated
December 20, 2019, with respect to the Registration Statement on Form S-4 that was filed by DLR with the Commission on December 6, 2019 (the “Proxy Statement/Prospectus”) in connection with the offer (the
“Offer”) to exchange each outstanding ordinary share of InterXion Holding N.V. (“INXN”) for 0.7067 shares of common stock of DLR. Capitalized terms used but not defined in this letter shall have the respective
meanings assigned to them in the Proxy Statement/Prospectus, as amended.

 The text of the Staff’s comments has been included in this
letter in bold for your convenience, and we have numbered the paragraphs below to correspond to the numbers in the Staff’s letter. For your convenience, our response to each of the numbered comments is set forth immediately below each numbered
comment. In our response to comment number 1, we have responded separately to each sentence in the comment in order to make sure that our response is comprehensive. DLR has filed Amendment No. 1 to the Proxy Statement/Prospectus with the
Commission that reflects the revisions described below.

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 Cover Page of the Proxy Statement/Prospectus

1.
 (a) With a view towards disclosure, please advise us as to the circumstances pursuant to which the
minimum condition would be reduced to sixty-six and two-thirds percent.

 Response: The eighty percent
minimum condition threshold is a contractual agreement between DLR, Buyer and INXN. DLR or Buyer would consider reducing the minimum condition to sixty-six and two-thirds percent if doing so was necessary in their view to consummate the closing of
the transactions contemplated by the purchase agreement, and DLR were to conclude that the tax consequences of doing so would be acceptable in its sole discretion. In the event that DLR or Buyer determines to reduce the minimum condition, DLR will,
as noted in the additional responses to Comment 1 below, disseminate additional offer materials and, if necessary to avoid any material misstatement or omission in the Proxy Statement/Prospectus, also supplement the disclosure of the Proxy
Statement/Prospectus, including with the most current available information with respect to potential material tax consequences, if any.

In response to this comment, we have amended the disclosure on page 33 of the Proxy Statement/Prospectus as follows:

The purchase agreement grants DLR or Buyer the right to reduce the minimum condition to sixty-six and two-thirds percent (66 2/3%). DLR or
Buyer may reduce the minimum condition to sixty-six and two-thirds percent (66 2/3%) without INXN consent, and if reduced, a lesser number of shares would be required to tender to close the offer. No further vote or other action on the part of any
shareholder of INXN or stockholder of DLR will be required if DLR or Buyer reduces the minimum condition. The eighty percent (80%) minimum condition threshold is a contractual agreement between DLR, Buyer and INXN. DLR or Buyer would
consider reducing the minimum condition to sixty-six and two thirds percent (66 2/3%) if doing so was necessary in their view to consummate the closing of the transactions contemplated by the purchase agreement and DLR were to conclude that the tax
consequences of doing so would be acceptable in its sole discretion. In the event that DLR or Buyer determines to reduce the minimum condition, DLR will, if necessary, supplement this proxy statement/prospectus including with the most current
available information with respect to potential material tax consequences, if any.

 (b) While the Buyer may amend the minimum
condition at any time during the initial offering period, changing it requires that Buyer amend the offer materials, disseminate information about the change and ensure that enough time remains in the initial offering period for INXN shareholders to
receive and react to the new information.

 Response: Buyer acknowledges the requirement that Buyer must announce any
decision to waive a material condition, including the minimum condition, in a manner reasonably calculated to inform INXN shareholders of the waiver. Buyer further acknowledges that in the event of any waiver of a condition to the Offer, the
applicable Exchange Act rules may require that the Offer be extended to the extent the waiver constitutes a material change to the Offer and the Offer would not otherwise remain open for a period sufficient for INXN shareholders to become reasonably
informed of such change.

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 (c) In addition, as it relates to the ownership percentage that DLR may own after the
offer, Buyer may be required to disseminate revised disclosure explaining the impact of this change. For example, in certain non-US jurisdictions, where a bidder cannot eliminate remaining target shareholders simply by acquiring a majority of the
target’s shares, lowering the minimum condition may require an explanation of the impact on a bidder’s ability to integrate the target company after the offer.

Response: We confirm that a reduction of the minimum condition will have no impact on the ownership percentage of INXN that Buyer
and DLR will own after the closing of the Offer and post-offer reorganization. Regardless of whether or not the minimum condition has been reduced, following implementation of the post-offer reorganization, if the required resolutions are adopted at
the EGM, Buyer and DLR will own either 100% of INXN’s equity or 100% of INXN’s assets.

 In response to this comment, we have
revised the disclosure on pages 18 and 82 as follows:

 Following the closing of the offer (including the closing of any shares tendered in
the subsequent offering period), DLR and INXN and their respective subsidiaries, as applicable, shall effectuate or cause to be effectuated the post-offer reorganization. DLR and Buyer have a preference for effectuating the legal merger, the legal
demerger or the asset sale. The post-offer reorganization will, if the required resolutions are adopted at the EGM, result in Buyer or one of its affiliates becoming the sole owner of all or substantially all of INXN’s business operations
from and after the consummation of such post-offer reorganization, regardless of whether or not all of the shareholders of INXN have tendered their shares in the offer or whether or not Buyer has lowered the minimum condition.

Please see also our response to Comment 16 below.

(d) Please revise the disclosure to affirm that registrants will provide shareholders with additional disclosure after any change in the
minimum condition and that the registrants will ensure that the offer remains open for an adequate time to allow shareholders to react to that new disclosure.

Response: In response to this comment, we have revised the disclosure on the first and second pages of the front cover and page
ALT-2 of the Proxy Statement/Prospectus to include the following statement at the end of the second paragraph:

 If Buyer makes a
material change in the terms of the offer or the information concerning the offer, or if it waives a material condition to the offer, including reducing the minimum condition, Buyer will disseminate additional offer materials and extend the offer by
five or ten business days, to the extent required by Rules 14d-4(d), 14d-6(c) and 14e-1 under the Securities Exchange Act of 1934, as amended, which we refer to as the Exchange Act. For example, if Buyer reduces the minimum condition, Buyer will
disseminate additional offer materials and extend the offer by five business days as required by Rule 14d-4(d)(2)(i) under the Exchange Act.

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 (e) In this regard, we understand from our conversation with Latham & Watkins
that the registrants will not be relying on the Tier II cross-border exemptions. Please confirm the registrants’ and Buyer’s understanding.

Response: We confirm that the registrants and Buyer will not be relying on the Tier II cross-border exemptions.

2.
 Disclosure indicates that “if INXN elects to hold a subsequent EGM, Buyer will extend the offer for six
business days after the date of that subsequent EGM.” Please revise the disclosure to explain the phrase “subsequent EGM” and describe the circumstances pursuant to which a subsequent EGM would be held. Please disclose the impact, if
any, the holding of a subsequent EGM would have on Buyer’s plans to provide a subsequent offering period.

Response: EGM is the term used to refer to the extraordinary general meeting of INXN shareholders. Under Dutch law, an EGM is
required to approve the adoption of resolutions providing for, among other things, the approval of certain transactions governed by Dutch corporate law as contemplated by the post-offer reorganization and the appointment of Buyer and DLR designees
to the INXN board of directors effective upon the closing of the transactions contemplated by the purchase agreement. Under the purchase agreement, if any of these resolutions are not approved at the EGM, a subsequent EGM may be held to make another
attempt to obtain the approval of the remaining outstanding resolutions. The approval and adoption of these resolutions is a condition to closing under the purchase agreement. As such, a subsequent EGM provides the parties with another opportunity
to satisfy this closing condition.

 We confirm that a subsequent offering period will be held, irrespective of whether a subsequent EGM is
held or not.

 In response to this comment, we have revised the disclosure on the third page of the front cover and page ALT-3 of the Proxy
Statement/Prospectus to include the following statement within the fourth paragraph:

 Under the purchase agreement, if any of the
resolutions of INXN that are a condition to closing are not approved and adopted at the EGM, a subsequent EGM may be held to obtain the approval of the remaining outstanding resolutions. Irrespective of whether INXN holds a subsequent EGM,
following the time of acceptance for payment in connection with the offer, which we refer to as the acceptance time, Buyer shall provide a subsequent offering period, which we refer to as a subsequent offering period, in accordance with
Rule 14d-11 promulgated under the Exchange Act of not less than three business days (calculated in accordance with Rule 14d-1(g)(3) under the Exchange Act).

Please see also our response to Comment 3 below.

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3.
 Disclosure indicates that “[f]ollowing the time of acceptance for payment in connection with the offer,
which we refer to as the acceptance time, Buyer shall provide a subsequent offering period, which we refer to as a subsequent offering period, in accordance with Rule 14d-11...of not less than three business days...” Please reconcile this
disclosure with disclosure on page 81 that “[p]arties do not anticipate commencing any subsequent offering period following the expiration time.”

Response: In response to this comment, we have revised the disclosure on pages 18, 82, 94 and ALT-12 as follows:

Parties do not anticipate commencing any subsequent offering period following the expiration time.

Irrespective of whether INXN holds a subsequent EGM, following the acceptance time, Buyer shall provide a subsequent offering period, in
accordance with Rule 14d-11 promulgated under the Exchange Act of not less than three business days (calculated in accordance with Rule 14d-1(g)(3) under the Exchange Act).

4.
 Refer to the disclosure described in the preceding comment. Disclosure on the last Q & A on page ALT-12
indicates that “[a]s promptly as practicable following the expiration time (but in any event within three business days thereafter), Buyer will accept for exchange and, at or as promptly as practicable
(but in any event within four business days thereafter), deliver the offer consideration... for all INXN shares validly tendered and not properly withdrawn pursuant to the offer as of the expiration time.” Please advise
whether such disclosure is suggesting that payment for tendered shares may occur four or seven business days after the expiration time and tell us why the registrants and Buyer believe this complies with the prompt payment requirement in Exchange
Act Rule 14e-1(c). In addition, if shares tendered in the initial offering period will not be accepted for up to three business days after expiration, please advise how the Buyer intends to comply with the time periods for announcing the results of
the offer and beginning the subsequent offering period immediately after expiration of the initial offer period. Refer to Exchange Act Rule 14d-11(c) and (d) and contrast such requirements with that of Exchange Act Rule 14d-1(d)(2)(v).

 Response: DLR acknowledges the Staff’s comment. Buyer will undertake to accept for exchange all
INXN shares validly tendered and not properly withdrawn immediately following the expiration of the Offer. Buyer will subsequently announce the results of the Offer by 9:00 a.m. Eastern time on the next business day after the expiration of the Offer
and announce the commencement of the subsequent offering period at that time. In order to satisfy the prompt payment requirement in Exchange Act Rule 14e-1(c), Buyer undertakes to deliver the offer consideration by the fourth business day following
the expiration of the initial offering period, and with respect to shares tendered in the subsequent offering period, Buyer undertakes to deliver the offer consideration as promptly as practicable following the expiration of such subsequent offering
period. Due to time differences between the Netherlands and eastern standard time (6 hours)

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such that the business day in the Netherlands will be over at the expiration of the Offer and certain Dutch law considerations in closing the post-offer reorganization transactions, DLR believes
that four business days are necessary to ensure the smooth delivery of the offering consideration and closing of the post-offer reorganization transactions. Accordingly, DLR believes that payment on the fourth business day following the expiration
of the initial offering period constitutes prompt payment in accordance with Rule 14e-1(c).

 In response to this comment, we have revised
the disclosure on page ALT-12 to reflect the timing outlined above as follows:

 As promptly as practicable
Immediately following the expiration time (but in any event within three business days thereafter), Buyer will accept for exchange and, at or as promptly as practicable (but in any
event within four business days by the fourth business day after the expiration time (calculated as set forth in Rule 14d-1(g)(3) promulgated under the Exchange Act) thereafter), deliver
the offer consideration (by delivery by Buyer of shares of DLR common stock to the exchange agent appointed by Buyer for the offer) fo