Untitled Document

Initial Letter Date

Form filed

Market Capitalization

04/13/2012

10-K

$ 7,500 M

You disclose on page [xx]that your valuation allowance was impacted by several of  your foreign entities continuing to incur losses during 2011. In future filings, please  quantify the amount of net deferred tax assets recognized for your material jurisdictions, along with the taxable income/(loss) recognized for the most recent fiscal year. This  disclosure will provide investors with context for the realizability of your deferred tax  assets disclosed by jurisdiction. Please refer to Section 501.14 of the Financial Reporting  Codification for guidance.