SEC Comment Letter for AMERICOLD REALTY TRUST (COLD) (CIK 0001455863) (COLD) — Apr 26, 2019
AMERICOLD REALTY TRUST (COLD) (CIK 0001455863)
Date: April 26, 2019 · CIK: 0001455863 · Accession: 0000000000-19-007668
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File numbers found in text: 001-34723
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April 26, 2019
Marc Smernoff
Chief Financial Officer
Americold Realty Trust
10 Glenlake Parkway, Suite 600, South Tower
Atlanta, Georgia 30328
Re:Americold Realty Trust
Americold Realty Operating Partnership, L.P.
Form 10-K For The Fiscal Year Ended December 31, 2018
Filed February 26, 2019
File No. 001-34723
Dear Mr. Smernoff:
We have limited our review of your filing to the financial statements and related
disclosures 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 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 our comment, we may have additional comments.
Form 10-K for the year ended December 31, 2018
Item 9A. Controls and Procedures, page 113
1.We note that management’s conclusion on disclosure controls and procedures as it relates
to Americold Realty Operating Partnership, L.P. was not included. Please clarify and
ensure future periodic filings include complete separate reports on disclosure controls and
procedures for both entities.
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.
You may contact Howard Efron, Staff Accountant, at (202) 551-3439 or Wilson K. Lee,
Senior Staff Accountant, at (202) 551-3468 with any questions.
FirstName LastNameMarc Smernoff
Comapany NameAmericold Realty Trust
April 26, 2019 Page 2
FirstName LastName
Marc Smernoff
Americold Realty Trust
April 26, 2019
Page 2
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities
cc: Jim Synder, Chief Legal Officer