IRON MOUNTAIN INCORPORATED
                               745 Atlantic Avenue
                                   10th Floor
                           Boston, Massachusetts 02111

                                                               September 5, 2001

VIA EDGAR AND FACSIMILE

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, DC 20549
Attn:  James Lopez

         Re:  Post-Effective  Amendment No. 1, filed on August 29, 2001, to Iron
         Mountain  Incorporated  Registration  Statement  on Form S-3  (File No.
         333-54030)

Ladies and Gentlemen:

         Iron  Mountain   Incorporated  (the  "Company")  and  its  subsidiaries
signatory  to  the   above-mentioned   Post-Effective   Amendment   No.  1  (the
"Co-Registrants")   hereby   request   consent   to   the   withdrawal   of  the
above-mentioned  Post-Effective Amendment No. 1 to the Registration Statement on
Form S-3 (the "Post-Effective Amendment") pursuant to Rule 477 promulgated under
the  Securities  Act of 1933, as amended,  effective  upon the date of filing of
this letter with the Securities and Exchange  Commission.  This request  relates
only to the  Post-Effective  Amendment  and not to the  underlying  Registration
Statement,  as  previously  declared  effective by the  Securities  and Exchange
Commission.   The  Company  and  the  Co-Registrants  filed  the  Post-Effective
Amendment to identify as co-registrants three additional  subsidiaries (the "New
Guarantors")  that might guarantee debt securities issued under the Registration
Statement.  The New Guarantors  were not obligated to issue  guarantees  and, at
this point, the Company has determined that they will not issue guarantees under
the Registration Statement.  Accordingly,  application is being made to withdraw
the  Post-Effective  Amendment.  We hereby confirm that no securities  have been
issued or sold under or pursuant to the Post-Effective Amendment.

         If you have any questions or comments or require further information or
documentation,  please do not hesitate to call the undersigned at (617) 535-4766
or William J. Curry,  Esq., of Sullivan & Worcester LLP,  outside counsel to the
Company, at (617) 338-2976.


                                             Sincerely,


                                             /s/  John F. Kenny, Jr.
                                             John F. Kenny, Jr.
                                             Executive Vice President & Chief
                                             Financial Officer of Iron Mountain
                                             Incorporated and each of the
                                             Co-Registrants

cc:      William J. Curry, Esq.
         Robert Zuccaro, Esq.