AW 1 imis_aw0905.txt IRON MOUNTAIN INCORPORATED 745 Atlantic Avenue 10th Floor Boston, Massachusetts 02111 September 5, 2001 VIA EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporate Finance 450 Fifth Street, N.W. Washington, DC 20549 Attn: James Lopez Re: Post-Effective Amendment No. 1, filed on August 29, 2001, to Iron Mountain Incorporated Registration Statement on Form S-3 (File No. 333-54030) Ladies and Gentlemen: Iron Mountain Incorporated (the "Company") and its subsidiaries signatory to the above-mentioned Post-Effective Amendment No. 1 (the "Co-Registrants") hereby request consent to the withdrawal of the above-mentioned Post-Effective Amendment No. 1 to the Registration Statement on Form S-3 (the "Post-Effective Amendment") pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended, effective upon the date of filing of this letter with the Securities and Exchange Commission. This request relates only to the Post-Effective Amendment and not to the underlying Registration Statement, as previously declared effective by the Securities and Exchange Commission. The Company and the Co-Registrants filed the Post-Effective Amendment to identify as co-registrants three additional subsidiaries (the "New Guarantors") that might guarantee debt securities issued under the Registration Statement. The New Guarantors were not obligated to issue guarantees and, at this point, the Company has determined that they will not issue guarantees under the Registration Statement. Accordingly, application is being made to withdraw the Post-Effective Amendment. We hereby confirm that no securities have been issued or sold under or pursuant to the Post-Effective Amendment. If you have any questions or comments or require further information or documentation, please do not hesitate to call the undersigned at (617) 535-4766 or William J. Curry, Esq., of Sullivan & Worcester LLP, outside counsel to the Company, at (617) 338-2976. Sincerely, /s/ John F. Kenny, Jr. John F. Kenny, Jr. Executive Vice President & Chief Financial Officer of Iron Mountain Incorporated and each of the Co-Registrants cc: William J. Curry, Esq. Robert Zuccaro, Esq.