United States securities and exchange commission logo
May 23, 2022
Andrew P. Power
President & Chief Financial Officer
Digital Realty Trust, Inc.
5707 Southwest Parkway, Building 1, Suite 275
Austin, TX 78735
Re: Digital Realty
Trust, Inc.
Digital Realty
Trust, L.P.
Form 10-K for the
Fiscal Year Ended December 31, 2021
Filed February 25,
2022
File No. 001-32336
Dear Mr. Power:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments. In some of our comments, we
may ask you to
provide us with information so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
Results of Operations, page 61
1. We note your disclosure
of results of operations includes a discussion of your stabilized
and non-stabilized
portfolio. Please consider expanding your disclosure to include a
discussion of the
changes to each portfolio from period to period including the additions,
subtractions and
transfers between each category.
Andrew P. Power
FirstName LastNameAndrew P. Power
Digital Realty Trust, Inc.
Comapany
May NameDigital Realty Trust, Inc.
23, 2022
May 23,
Page 2 2022 Page 2
FirstName LastName
2. Please consider expanding your disclosure to quantify all the factors
that had a significant
impact on operations from period to period. For example, we note that
the completion of
a global development pipeline, expansion into new markets in EMEA and
property sales
all contributed to the change in non-stabilized rental and other
services revenue during the
period. However, it does not appear that the impact of these items has
been quantified in
your MD&A.
Item 8. Financial Statements and Supplementary Data
Note 2. Summary of Significant Accounting Policies
Capitalization of Costs, page 105
3. We note your disclosure that direct and indirect leasing costs
associated with the
acquisition of tenants are capitalized. Please tell us how determined
it was appropriate to
capitalize indirect costs. Reference is made to ASC Topic 842-10-30-9
through 10; and
ASC Topic 842-30-25-10. In your response, tell us the amount of
indirect costs
capitalized in each period presented in your financial statements.
In closing, 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.
You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Robert
Telewicz,
Accounting Branch Chief at (202) 551-3438 with any questions.
Sincerely,
Division of
Corporation Finance
Office of Real
Estate & Construction