TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo April 10, 2023 Brendan T. Cavanagh Chief Financial Officer SBA Communications Corporation 8051 Congress Avenue Boca Raton, FL 33487 Re: SBA Communications Corporation Form 10-K for fiscal year ended December 31, 2022 Filed March 1, 2023 Form 8-K filed February 21, 2023 File Nos. 001-16853 Dear Brendan T. Cavanagh: We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10-K for fiscal year ended December 31, 2022 Consolidated Financial Statements Notes to Consolidated Financial Statements 3. Fair Value Measurements Items Measured at Fair Value on a Nonrecurring Basis, page F-17 1. We note your long-lived and intangible assets are measured at fair value on a nonrecurring basis using Level 3 inputs under a discounted cash flow model. In future periodic filings, please provide quantitative information about the significant unobservable inputs used in the fair value measurement of these assets or tell us why such disclosure is not required. Refer to ASC 820-10-50-2(bbb). Brendan T. Cavanagh SBA Communications Corporation April 10, 2023 Page 2 Form 8-K filed February 21, 2023 Exhibit 99.1 Funds from Operations ("FFO"), Adjusted Funds from Operations ("AFFO"), and AFFO per share, page 15 2. We note your presentation of AFFO per share and the related forecasted guidance. In future earnings releases, please reconcile these non-GAAP financial measures from the the most directly comparable measure calculated in accordance with GAAP. Refer to Item 10(e)(1)(i)(B) of Regulation S-K and Question 102.10(a) of the Division's Non- GAAP Financial Measures Compliance and Disclosure Interpretations. In closing, 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. You may contact Isaac Esquivel at (202) 551-3395 or Mark Rakip at (202) 551-3573 with any questions. FirstName LastNameBrendan T. Cavanagh Sincerely, Comapany NameSBA Communications Corporation Division of Corporation Finance April 10, 2023 Page 2 Office of Real Estate & Construction FirstName LastName