CCICrown Castle

We note your disclosure that in light of the impairment of the Fiber segment goodwill of approximately $5 billion, the Company conducted a review during the fourth quarter of 2024, including analysis of both market-level and segment-level information, and determined there was no impairment of its Fiber segment long-lived assets.

Rest of the question

In performing your impairment testing, please tell us how you considered the guidance in ASC 350-20-35-31 in performing your recoverability test for your longlived assets prior to your goodwill impairment test and how that may have impacted such analysis, if any. Condensed Consolidated Statement of Operations and Comprehensive Income (Loss), page 4 We note your presentation of income (loss) from discontinued operations before gain (loss) from disposal, net of tax and gain (loss) from disposal of discontinued 2. operations, net of tax. Please tell us how your disclosure complies with ASC 205-2045-3A, which requires disclosure of the tax impact of all discontinued operations as a separate component of income or loss. In addition, please reconcile the difference between the $830 million reported as loss from disposal of discontinued operations, net of tax and the $819 million reported as valuation allowance for assets held for sale in your table on page 9.

The Company acknowledges the Staff's comment and confirms that, in accordance with ASC 350-20-35-31, the Company had performed the impairment analysis of its Fiber segment long-lived assets prior to performing the goodwill impairment analysis and concluded there was no impairment of long-lived assets identified.

Rest of the answer

This assessment had no impact on the goodwill impairment analysis or the amount of loss recorded for goodwill impairment in the fourth quarter of 2024.

The Company advises the Staff that its Fiber segment represents both: a) an asset group for purposes of evaluating long-lived assets, as the lowest level for which identifiable discrete cash flows (including projected cash flows) are largely independent of the cash flows of other groups of assets is the overall Fiber segment level; and b) a reporting unit for purposes of evaluating goodwill.

With respect to long-lived assets, in accordance with ASC 360-10-35-17 and per the Company's policy on page 49 of the Form 10-K, "if the sum of the associated estimated future cash flows (undiscounted) from an asset group is less than its carrying amount, an impairment loss may be recognized. If the carrying value were to exceed the undiscounted cash flows, measurement of an impairment loss would be based on the fair value of the asset, which is based on an estimate of discounted future cash flows." Pursuant to the policy noted above, management reviews projected undiscounted cash flows at the Fiber segment level to evaluate potential impairment of the long-lived Fiber asset group. For purposes of this analysis, management utilized the undiscounted cash flow projections included in the model it uses for budgeting and forecasting purposes as well as in the calculation of the estimated fair value of the Fiber reporting unit when conducting the quantitative goodwill impairment analysis. The Company noted that the undiscounted cash flows of the Fiber asset group exceeded the carrying value and determined there was no impairment.

Additionally, as a supplement to this undiscounted cash flow analysis, for the Fiber segment, management annually evaluates historical trends of certain key financial performance indicators related to the major U.S. markets (using the Core Based Statistical Areas) where the Company has made significant investments for indicators of impairment of its long-lived assets in the respective markets. During 2024, management reviewed these financial performance indicators of such markets comprising the majority of the Company's Fiber segment long-lived assets balance and noted no indications of impairment.

In conclusion, for the year ended December 31, 2024, the Company confirms there was no impairment of its Fiber segment long-lived assets resulting from its analysis, which was conducted prior to the goodwill impairment analysis. The cash flow model utilized in the long-lived asset impairment analysis is the same model utilized in the goodwill impairment analysis, except that goodwill is evaluated using the fair value (i.e., discounted cash flows), whereas the long-lived assets are evaluated using undiscounted cash flows. As disclosed in the Form 10-K, an impairment of the Fiber segment's goodwill was recorded in the fourth quarter 2024 as a result of that analysis.

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