Published on June 25, 2019
June 25, 2019
Thomas Olinger
Chief Financial Officer
Prologis, Inc.
Prologis, L.P.
Pier 1, Bay 1
San Francisco, CA 94111
Re: Prologis, Inc. and Prologis, L.P.
Form 10-K for the year ended December 31, 2018
Filed February 13, 2019
File No. 001-13545 and File No. 001-14245
Dear Mr. Olinger:
We have reviewed your June 12, 2019 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to our comment 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
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to our comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our May 30, 2019 letter.
Form 10-K for the year ended December 31, 2018
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Same Store Analysis, page 28
1. We note your response to comment 1 and your proposed disclosure. We
continue to be
unclear how you determined it was appropriate to include 100% of property
NOI from
unconsolidated co-investment ventures included in same store portfolio
within O&M
same store property NOI - net effective and O&M same store property NOI -
cash. Please
advise or confirm that you will revise future filings to not combine 100%
of property NOI
from unconsolidated co-investment ventures with consolidated property
NOI.
You may contact Howard Efron, Staff Accountant, at (202)551-3439 or
Jennifer Monick,
Thomas Olinger
Prologis, Inc.
June 25, 2019
Page 2
Assistant Chief Accountant, at (202) 551-3295 if you have questions regarding
comments on the
financial statements and related matters.
Sincerely,
FirstName LastNameThomas Olinger Division of
Corporation Finance
Office of Real Estate
and
Comapany NamePrologis, Inc.
Commodities
June 25, 2019 Page 2
cc: Lori Palazzolo
FirstName LastName