May 15, 2017
Eric McPhee
United States Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
RE: Crown Castle International Corp.
Form 10-K for the fiscal year ended December 31, 2016
Filed February 22, 2017
Form 8-K dated January 25, 2017
Filed January 25, 2017
File No. 1-16441
Dear Mr. McPhee:
We are responding to your recent letter in which you provided comment on the Crown Castle International Corp. (“Company”) Form 10-K for the fiscal year ended December 31, 2016 filed on February 22, 2017 (“Form 10-K”) and the Company’s Form 8-K dated and filed January 25, 2017 (“Form 8-K”). For the convenience of the Staff, the Staff’s comment is reproduced and is followed by the Company’s response.
Staff Comment:
Form 8-K filed January 25, 2017
Exhibit 99.1
We note your presentation of the measure site rental gross margin. As this measure appears to be a non-GAAP measure, in future filings please provide the disclosures required by Item 10(e)(1)(i) of Regulation S-K.
Company Response:
We acknowledge the Staff’s comment and, in future filings, we will provide the disclosures required by Item 10(e)(1)(i) of Regulation S-K with respect to our presentation of site rental gross margin.
* * * *
If you would like to discuss our responses to the comment or if you would like to discuss any other matters, please contact the undersigned at (713) 570-5105. In my absence, please contact Ken Simon, Senior Vice President and General Counsel at (713) 570-5101.
1
Sincerely, |
/s/ Daniel K. Schlanger |
Daniel K. Schlanger Senior Vice President and Chief Financial Officer |
cc: Howard Efron
2