United States securities and exchange commission logo
June 17, 2024
Andrew Power
President & Chief Executive Officer
Digital Realty Trust, Inc.
5707 Southwest Parkway, Building 1, Suite 275
Austin, TX 78735
Re: Digital Realty
Trust, Inc.
Form 10-K for the
year ended December 31, 2023
Form 8-K filed May
2, 2024
File No. 001-32336
Dear Andrew Power:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 8-K filed May 2, 2024
Exhibit No. 99.1
Definitions, page 31
1. We note that your
measures Core FFO and Adjusted EBITDA contain adjustments for
other non-core items.
Please tell us what types of revenues or expenses are being added
back, and to the extent
that these are significant to the non-GAAP measure in future
filings, please provide
further explanation within your disclosure.
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.
Please contact Eric McPhee at 202-551-3693 or Wilson Lee at
202-551-3468 with any
questions.
Andrew Power
Digital Realty Trust, Inc.
June 17, 2024
Page 2
FirstName LastNameAndrew Power Sincerely,
Comapany NameDigital Realty Trust, Inc.
Division of Corporation Finance
June 17, 2024 Page 2 Office of Real Estate & Construction
FirstName LastName