EQIXEquinix

We note your presentation of the non-GAAP financial measure Adjusted EBITDA presented on an entity-level basis reconciled from Income from operations rather than Net income. As you are providing a performance measure, in future periodic filings please revise to reconcile this measure from consolidated Net income as the most directly comparable measure calculated in accordance with GAAP.

Rest of the question

Refer to Question 103.02 of the Division's Compliance and Disclosure Interpretations for Non-GAAP Financial Measures. Item 15. Exhibits, Financial Statement Schedules Financial Statements Notes to Consolidated Financial Statements 17. Segment Information, page F-61

Equinix acknowledges the Staff’s comment and confirms that Equinix will revise its disclosure in future periodic filings to reconcile Adjusted EBITDA to consolidated net income rather than income from operations. We expect that this disclosure will be substantially similar to the reconciliation included in Appendix A, which has been illustratively amended for the Staff’s comment. Read in the reply ↗

We note your segment measure of profit or loss is reconciled to Income from operations as presented in your consolidated statements of operations. In future periodic filings, please reconcile your segments' measure of profit or loss to consolidated Income before income taxes. Refer to ASC 280-10-50-30b.

Equinix acknowledges the Staff’s comment and confirms that Equinix will revise its disclosure in future periodic filings to reconcile the segments’ measure of profit or loss to consolidated income before income taxes rather than income from operations. We expect that this disclosure will be substantially similar to the reconciliation included in Appendix B, which has been illustratively amended for the Staff’s comment. Read in the reply ↗

Revenue Recognition, page F-23 1. We note that a "majority" of your $8.4 billion remaining performance obligations will be recognized in 24 months. Considering your multi-year arrangements, please tell us in what periods you expect to recognize the amounts included in the "majority" and how your current disclosures reflect the appropriate time bands for your arrangements.

Rest of the question

In that regard, please tell us how you considered disclosure around revenue expected to be recognized within 1 year, 2 years etc. Refer to ASC 606-10-50-13(b). 17. Segment Information, page F-63 2. We note your disclosure of revenues by geographical area, including “Americas, EMEA and Asia-Pacific.” Please explain to us how your disclosure complies with ASC 280-10-50-41(a) which requires separate disclosure of revenues attributed to your country of domicile. Otherwise, confirm that you will revise your future filings to include such information including any revenues attributed to individual foreign countries, to the extent material.

With respect to the Staff’s comment regarding revenues attributed to our country of domicile, Equinix respectfully advises the Staff that we disclosed our total revenues attributed to the United States (U.S.), our country of domicile, as footnote 2 to the disaggregated revenue information tables within “Footnote 17: Segment Information” of our annual consolidated financial statements in our Form 10-K for the fiscal year ended December 31, 2020 (page F-63 and F-64).

Rest of the answer

In future filings, we will make the disclosure more prominent by moving it to the main body of “Footnote 17: Segment Information” as a separate paragraph.

With respect to the Staff’s comment regarding any revenues attributed to individual foreign countries, we analyze our revenues of individual foreign countries during each reporting period in accordance with ASC 280-10-50-41(a). No foreign country’s revenues from our external customers have represented greater than 10% of our total revenues, and none are considered to be significantly different on a qualitative basis necessitating further disclosure. To ensure clarity on this point, we will include the following disclosure in future filings: “There is no country outside of the U.S. from which we derived revenues that exceeded 10% of our total revenues.” We will continue to monitor our revenues for all countries and will separately disclose in our future filings revenues in any individual country that exceed 10% of our total revenues for such reporting period.

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