0001193125-12-205488.txt : 20120604 0001193125-12-205488.hdr.sgml : 20120604 20120502200211 ACCESSION NUMBER: 0001193125-12-205488 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20120502 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SBA COMMUNICATIONS CORP CENTRAL INDEX KEY: 0001034054 STANDARD INDUSTRIAL CLASSIFICATION: COMMUNICATION SERVICES, NEC [4899] IRS NUMBER: 650716501 STATE OF INCORPORATION: FL FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 5900 BROKEN SOUND PARKWAY CITY: BOCA RATON STATE: FL ZIP: 33487 BUSINESS PHONE: 5619957670 MAIL ADDRESS: STREET 1: 5900 BROKEN SOUND PARKWAY CITY: BOCA RATON STATE: FL ZIP: 33487 CORRESP 1 filename1.htm Correspondence

SBA Communications Corporation

5900 Broken Sound Parkway NW

Boca Raton, Florida 33487

May 2, 2012

Sharon Virga

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549-3561

 

   Re:    SBA Communications Corporation
      Form 10-K for the fiscal year ended December 31, 2011
      Filed February 27, 2012
      File No. 0-30110

Dear Ms. Virga:

SBA Communications Corporation (“SBA”) hereby acknowledges receipt of the comments provided by the Staff of the Securities and Exchange Commission (“Commission”) in its letter dated April 12, 2012. As previously discussed with Kara MacCullough of Greenberg Traurig, P.A., in accordance with SBA’s prior submissions to, and discussions with, the Office of the Chief Accountant, SBA believes that it has complied with all disclosure requirements associated with the Master Agreement executed with one of SBA’s wireless service provider customers.

This letter confirms that SBA acknowledges that:

 

  •  

SBA is responsible for the adequacy and accuracy of the disclosure in the filing;

 

  •  

The Staff’s comments or changes to disclosure in response to the Staff’s comments do not foreclose the Commission from taking any action with respect to the filing; and

 

  •  

SBA may not assert the Staff’s comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

We appreciate the Staff’s assistance with regard to this matter. Please direct any questions, comments or requests for further information to the undersigned at (561) 226-9335 or our counsel, Kara MacCullough, at (954) 768-8255.

 

Very truly yours,
/s/ Brendan T. Cavanagh
Brendan T. Cavanagh
Chief Financial Officer
SBA Communications Corporation