United States securities and exchange commission logo

                           August 21, 2020

       Scott G. Bruce
       Digital Landscape Group, Inc.
       660 Madison Avenue, Suite 1435
       New York, NY 10065

                                                        Re: Digital Landscape
Group, Inc.
Statement on Form S-4
                                                            Filed July 29, 2020
                                                            File No. 333-240173

       Dear Mr. Bruce:

              We have reviewed your registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our July
9, 2020 letter.

       Form S-4 filed July 29, 2020

       Unaudited Pro Forma Condensed Combined Financial Information
       Items Not Adjusted in the Unaudited Pro Forma Condensed Combined
Financial Information,
       page 63

   1.                                                   We note your response
to prior comment 12. We note that the compensation paid to the
                                                        Associated Partners
management team related only to Associated Group Management   s
                                                        management of the
investments in the APW Group and other Associated Partners
                                                        portfolio companies. We
also note that following the APW Acquisition, the company   s
                                                        business encompasses
both the investment management role formerly performed at the
                                                        Associated Group
Management level and the business operations previously conducted at
                                                        the APW Group level. As
it appears the activities formerly performed by the Associated
 Scott G. Bruce
FirstName  LastNameScott  G. Bruce
Digital Landscape Group, Inc.
August  21, NameDigital
            2020        Landscape Group, Inc.
Page  2 21, 2020 Page 2
FirstName LastName
         Partners management team will continue post acquisition, please
provide more details of
         why you believe that such costs should not be allocated to APW Group
and reflected in its
         historical consolidated statements of operations.
Management   s Discussion and Analysis of Financial Condition and Results of
EBITDA and Adjusted EBITDA, page 73

2.       We note your response to prior comment 4. We note that you continue to
disclose on
         page 74 your estimate of the historical selling, general, and
administrative costs related to
         the acquisition of revenue producing assets. As previously requested,
please tell us why
         you believe this disclosure is appropriate and provides useful
information to investors
         regarding your financial condition and results of operations. In your
response please tell
         us how you estimated such costs and include a discussion of the
frequency with which you
         have acquired revenue producing assets in the past, and whether you
expect that trend to
         continue in future periods.
Acquisition Capex, page 74

3.       We note your response to prior comment 5. It appears that your measure
of Acquisition
         Capex is designed to reflect costs incurred to acquire revenue
producing assets as assets
         before they meet the criteria to be capitalized in accordance with US
GAAP. Please
         explain to us how you considered the guidance in question 100.04 of
the Compliance
         & Disclosure Interpretations related to Non-GAAP Financial Measures in
         whether the measure employs a tailored accounting principle. In your
response, please
         explain to us how your measure is designed to ensure that committed
         payments are not included as investments in real property interests in
the subsequent
Annualized In-Place Rents, page 75

4.       We note your response to prior comment 7. Given the limitation of
providing a
         quantitative reconciliation of this measure, please tell us how you
considered discussing
         the difference between your revenue recognition policy and your
calculation of annualized
         in-place rents. Also, revise to discuss why management believes the
presentation of this
         measure provides valuable additional information for users of the
financial statements in
         assessing your financial performance and growth.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
 Scott G. Bruce
Digital Landscape Group, Inc.
August 21, 2020
Page 3

       You may contact Jorge Bonilla at 202-551-3414 or Robert Telewicz at
202-551-3438 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Ruairi Regan at 202-551-3269 or Maryse Mills-Apenteng at 202-551-3457
with any
other questions.

FirstName LastNameScott G. Bruce
                                                          Division of
Corporation Finance
Comapany NameDigital Landscape Group, Inc.
                                                          Office of Real Estate
& Construction
August 21, 2020 Page 3
cc:       D. Scott Bennett, Esq.
FirstName LastName