United States securities and exchange commission logo November 12, 2020 Jeffrey A. Stoops Chief Executive Officer, President and Director SBA Communications Corporation 8051 Congress Avenue Boca Raton, Florida 33487 Re: SBA Communications Corporation Registration Statement on Form S-4 Filed November 6, 2020 File No. 333-249893 Dear Mr. Stoops: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Ronald (Ron) Alper at 202-551-3329 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Kara MacCullough