January 17, 2020

Via E-mail
Julian T.H. Kleindorfer, Esq.
Latham & Watkins LLP
355 South Grand Avenue, Suite 100
Los Angeles, California 90071-1560

       Re:    Digital Realty Trust, Inc.
              Amendment No. 1 to Registration Statement on Form S-4
              Filed January 7, 2020
              File No. 333-235380

Dear Mr. Kleindorfer:

        We have reviewed the amended registration statement and your response
letter and have
the following comments.

1.     Refer to your response "1(d)" and the disclosure revised in response to
prior comment 1.
       The disclosure indicates that "if Buyer reduces the minimum condition,
Buyer will
       disseminate additional offer materials and extend the offer by five
business days as
       required by Rule 14d-4(d)(2)(i) under the Exchange Act." While the Buyer
may choose
       to extend the offer by five business days, the rule only requires that
the offer must remain
       open five business days from the date that material changes to the
tender offer materials
       are disseminated to security holders.

2.     We note your response to prior comment 4 that DLR believes that payment
on the fourth
       business day following the expiration of the initial offering period
constitutes prompt
       payment in accordance with Exchange Act Rule 14e-1(c). Please expand
upon your
       response regarding "certain Dutch law considerations in closing the
post-offer
       reorganization transactions" and why such considerations leads DLR to
its conclusion.
       While Exchange Act Rule 14e-1(c) does not define "promptly," the
Commission has
       stated that this standard may be determined by the practices of the
financial community,
       including current settlement practices and that in most cases, the
current settlement
       practice is for the payment of funds and delivery of securities no later
than the third
       business day after the date of the transaction. Refer to the guidance in
Exchange Act
       Release No. 43069, section II.D.

3.     In addition, your response to prior comment 4 indicates that with
respect to shares
       tendered in the subsequent offering period, Buyer undertakes to deliver
the offer
       consideration "as promptly as practicable following the expiration of
such subsequent
       offering period." Please refer to Exchange Act 14d-11(e), which requires
that the bidder
 Julian T.H. Kleindorfer, Esq.
Latham & Watkins LLP
January 17, 2020
Page 2

       immediately accept and promptly pay for all securities as they are
tendered during the
       subsequent offering period. Given your response, please advise how the
Buyer's
       undertaking is consistent with its obligations under Exchange Act
14d-11(e).

4.     The response to prior comment 9 indicates that if the purchase agreement
were to be
       terminated following the expiration time but prior to the acceptance
time (which section
       2.01(b) of the Purchase Agreement defines as any time within three
business days
       following the expiration time), and that all the offer conditions had
been satisfied or
       waived at the expiration time, Buyer would have the obligation to
consummate the offer.
       Your response to prior comment 13 indicates that there are no
circumstances pursuant to
       which the tender offer would be consummated and INXN would not become a
wholly
       owned subsidiary of DLR and its affiliates, provided that the required
resolutions were
       adopted at the EGM of INXN. Please confirm and disclose, if true, that
under no
       circumstances, will the condition to the offer regarding adoption of the
EGM resolutions
       be waived. Alternatively, disclose the risk that the offer could be
consummated even
       though the purchase agreement is terminated, resulting in the Buyer only
acquiring eighty
       percent (80%) of the outstanding INXN shares on a fully-diluted and
as-converted basis
       (or less to the extent the minimum condition was reduced). Include in
such disclosure a
       discussion of the impact this may have on DLR's ability to integrate
INXN after the
       offer, given any potential restrictions under Dutch law, including
restrictions on DLR's
       ability to eliminate remaining shareholders of INXN.

5.     We note your response to prior comment 14. If Buyer is required to
commence a
       compulsory acquisition and the Enterprise Chamber of the Amsterdam Court
of Appeals
       determines the cash price to be paid for the non-tendered shares, please
advise how such
       cash price is assured to be equal to at least the highest consideration
offered in the
       exchange offer.

                                             *   *   *

       Please contact me at (202) 551-3444 with any questions.

                                                           Sincerely,

                                                           /s/ Perry J. Hindin

                                                           Perry J. Hindin
                                                           Special Counsel
                                                           Office of Mergers
and Acquisitions