IRMIron Mountain

Segment Information, page 118 1. We note your chief operating decision maker (CODM) uses Adjusted EBITDA as the basis for evaluating the performance and allocating resources to operating segments. We also note your footnote 1 on page 119, that “Other Reportable Segment Expenses” primarily relates to Cost of sales (excluding depreciation and amortization) and Selling, general and administrative expenses for the

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respective reportable segment.” We also note your disclosure on page 118 that “[o]ther significant expenses regularly provided to the CODM include total Restructuring and other transformation costs…” Please tell us whether “Other Reportable Segment Expenses” represents other segment items disclosed pursuant to ASC 280-10-50-26B and 50-26C, and if so, how the Company has explained the nature of the expense information the CODM uses to manage operations as required by ASC 280-10-50-26C. See also ASC 280-10-5515G.

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Please expand your discussion of the reasons you believe that your leadership structure is appropriate, addressing your specific characteristics or circumstances. In your discussion, please also address the circumstances under which you would consider having the Chair and CEO roles filled by a single individual, when shareholders would be notified of any such change, and whether you will seek prior input from

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shareholders.

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Please expand upon the role that your Independent Chairman plays in the leadership of the board. For example, please enhance your disclosure to address whether or not your Independent Chairman may: • represent the board in communications with shareholders and other stakeholders; • require board consideration of, and/or override your CEO on, any risk matters; or • provide input on design of the board itself.

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Please expand upon how your board administers its risk oversight function. For example, please disclose: • the timeframe over which you evaluate risks (e.g., short-term, intermediate-term, or long-term) and how you apply different oversight standards based upon the immediacy of the risk assessed; • whether you consult with outside advisors and experts to anticipate future threats and trends, and how often you

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re-assess your risk environment; • how the board interacts with management to address existing risks and identify significant emerging risks; • whether you have a Chief Compliance Officer and to whom this position reports; and • how your risk oversight process aligns with your disclosure controls and procedures.

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