0001104659-13-045365.txt : 20130701 0001104659-13-045365.hdr.sgml : 20130701 20130529170735 ACCESSION NUMBER: 0001104659-13-045365 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20130529 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CubeSmart CENTRAL INDEX KEY: 0001298675 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 201024732 STATE OF INCORPORATION: MD FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 460 E. SWEDESFORD ROAD STREET 2: SUITE 3000 CITY: WAYNE STATE: PA ZIP: 19087 BUSINESS PHONE: 610-293-5700 MAIL ADDRESS: STREET 1: 460 E. SWEDESFORD ROAD STREET 2: SUITE 3000 CITY: WAYNE STATE: PA ZIP: 19087 FORMER COMPANY: FORMER CONFORMED NAME: U-Store-It Trust DATE OF NAME CHANGE: 20040727 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CubeSmart, L.P. CENTRAL INDEX KEY: 0001300485 STANDARD INDUSTRIAL CLASSIFICATION: REAL ESTATE INVESTMENT TRUSTS [6798] IRS NUMBER: 000000000 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 460 E. SWEDESFORD ROAD STREET 2: SUITE 3000 CITY: WAYNE STATE: PA ZIP: 19087 BUSINESS PHONE: 610-293-5700 MAIL ADDRESS: STREET 1: 460 E. SWEDESFORD ROAD STREET 2: SUITE 3000 CITY: WAYNE STATE: PA ZIP: 19087 FORMER COMPANY: FORMER CONFORMED NAME: U-Store-It L P DATE OF NAME CHANGE: 20041115 FORMER COMPANY: FORMER CONFORMED NAME: Acquiport Amsdell I L P DATE OF NAME CHANGE: 20040812 CORRESP 1 filename1.htm

 

Via EDGAR

 

Daniel L. Gordon

Division of Corporation Finance

Securities and Exchange Commission

100 F St. Street, NE

Washington, D.C. 20549

 

Re:                             CubeSmart
Form 10-K for Fiscal Year Ended December 31, 2012
Filed February 28, 2013
File No. 001-32324

 

CubeSmart, L.P.
Form 10-K for Fiscal Year Ended December 31, 2012
Filed February 28, 2013
File No. 000-54662

 

Dear Mr. Gordon:

 

Reference is made to the Staff’s comment letter dated May 15, 2013 to Timothy M. Martin, Chief Financial Officer of CubeSmart and CubeSmart, L.P. (collectively, the “Company”) regarding the above-referenced filings (the “Comment Letter”). This letter responds to the Comment Letter. For convenience, we have reproduced below the comment in the Comment Letter and the Company’s response.

 

Management’s Report on CubeSmart Internal Control over Financial Reporting, page F-2

 

1.              Comment: In future filings, please confirm to us that you will separately assess internal control over financial reporting and provide separate reports on management’s assessment of internal control over financial reporting for CubeSmart and CubeSmart LP.

 

Response: In our future filings, we will separately assess internal control over financial reporting and provide separate reports on management’s assessment of internal control over financial reporting for each of CubeSmart and CubeSmart L.P.

 

In responding to the Staff’s comments, the Company acknowledges that:

 

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

 

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

 

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

 

 

 

Sincerely,

 

 

 

CubeSmart

 

 

 

/s/ Timothy M. Martin

 

Timothy M. Martin
Chief Financial Officer

 

 

 

CubeSmart, L.P.

 

 

 

By: CubeSmart, its general partner

 

 

 

/s/ Timothy M. Martin

 

Timothy M. Martin
Chief Financial Officer