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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