AREAlexandria Real Estate Equities

We note your presentation of Revenue, as adjusted for use in the calculation of Adjusted EBITDA Margin, and that such non-GAAP measure includes an adjustment for the expense line item impairment of non-relate estate investments, as well as adjustments for amounts for select realized gains on non-real estate investments not classified as Revenue within your Statements of Operations.

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Please address the following: • Tell us how you determined Revenue to be considered the most directly comparable GAAP measure, given you adjust for an expense-related line item, as well as for certain realized gains that are a component of investment income. Refer to Item 10(e)(1)(i)(A) of Regulation S-K; • Tell us how you selected the "significant" realized gains to be excluded from your calculation of the non-GAAP measure Revenues, as adjusted; • Tell us how you determined that you have not presented an individually tailored measure given the adjustments referenced above; refer to Question 100.04 of the Division’s Non-GAAP Financial Measures Compliance & Disclosure Interpretations. 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.

The Company believes that its presentation of Adjusted

EBITDA margin and its components complies with the Staff’s rules and guidance regarding non-GAAP financial measures and that Revenue, as adjusted, which was used for the purpose of calculating Adjusted EBITDA margin, does not involve an individually tailored measure.

However, the Company confirms to the Staff that, in future periodic reports, the Company will discontinue adjusting its Revenues from the statement of operations when calculating Adjusted EBITDA margin.

As detailed in the table below, the impact of the

Company’s revenue

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adjustments on Adjusted EBITDA margins reported since the beginning of 2019 was not significant (3% or less) and had generally resulted in disclosure of lower Adjusted EBITDA margins:

Alexandria

Real Estate Equities, Inc.

Adjusted EBITDA Margin

Nine Months Ended

Year Ended December 31,

September 30, 2021

2020

2019

As reported

69 %

68 %

Prospective presentation

72 %

71 %

The following background is presented to assist in answering the questions contained in the Staff’s comments.

The Company presents Adjusted EBITDA margin because the Company believes that this supplemental performance measure provides investors with additional useful information regarding the profitability of the Company’s operating activities. This measure allows investors to evaluate the Company’s performance from period to period on a consistent basis without having to account for differences recognized because of investing and financing decisions related to the Company’s real estate and non-real estate investments, capital structure, capital market transactions, and variances resulting from the volatility of market conditions outside of the Company’s control.

Consistent with financial margin profitability measures, the Company’s calculation of the Adjusted EBITDA margin represents the quotient of Adjusted EBITDA (the numerator) and the revenues that generated the earnings (the denominator). The Company determined that Revenues, as presented in the Company’s statement of operations, is the most directly comparable GAAP measure to reconcile the denominator in our margin calculation, Revenue, as adjusted.

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The Company’s Adjusted EBITDA includes income from rentals and other income classified as Revenue, as well as the realized gains or losses related to the Company’s non-real estate investments classified as investment income, and excluded from total revenues, in the Company’s statements of operations. As a result, when presenting the denominator for the Adjusted EBITDA margin calculation, the Company used the Revenue from its statements of operations plus the realized investment gains or losses to present a more precise margin calculation, by making the numerator and denominator reflect the same components of rental operations and investment activity. The computation of Revenues, as adjusted, was provided exclusively for the purpose of computing Adjusted EBITDA margin and was not intended to be a separate operating measure.

As noted by the Staff, one of the adjustments made by the Company to the Adjusted EBITDA and Revenues, as adjusted, for purposes of calculating its Adjusted EBITDA margin has been significant realized gains on the Company’s non-real estate investments. The Company believes that adjusting for the effects of significant gains on the sale of non-real estate investments allows investors to evaluate performance from period to period on a consistent basis without having to account for differences recognized because of investing decisions related to the Company’s non-real estate investments that may not be representative of its operating performance. The Company excludes these transactions that occur from time to time because the Company believes it provided for an Adjusted EBITDA margin calculation that is more comparable across periods. Since the beginning of 2019, the Company excluded significant realized gains on non-real estate investments, all of which were $15 million or greater per individual investment transaction.

Consistent with the Staff’s guidance, the

Company considered the following questions in determining that Revenues, as adjusted is not an individually tailored accounting measure as described in Question 100.04 of the Division’s Non-GAAP Financial Measures Compliance & Disclosure Interpretations:

1. Does the adjustment shift the measure from an accrual basis of accounting to a cash or modified basis of accounting?

The adjustments to Revenues from the statement of operations that the Company included to calculate Revenues, as adjusted for the purpose of presenting Adjusted EBITDA margin did not shift the measure of revenue from an accrual basis of accounting to a cash or modified basis of accounting. Instead, the Company adjusted

Revenues from the statement of operations with other accrual basis amounts contained elsewhere in the Company’s statement of operations.

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