Untitled Document

Initial Letter Date

Form filed

Market Capitalization

09/12/2012

10-K

$ 1,010 M

We note that prior to September 30, 2010 you maintained a full valuation allowance for your  net deferred tax assets, since the likelihood of realization of those assets had not become  more likely than not. Effective September 30, 2010 you believed that sufficient positive evidence existed from historical operations and future income projections to conclude that it  was more likely than not to fully realize your federal deferred tax assets and to partially realize your state of California deferred tax assets. Please provide a more detailed  explanation as to how you determined it is more likely than not that you will realize total deferred tax assets. Please ensure your disclosures address each of the following points, as appropriate:  To the extent that you are relying on future pre-tax income, please disclose the amount of  pre-tax income that needs to be generated to realize your deferred tax assets. Please also include an explanation of the anticipated future trends included in your projections of  future taxable income.

If you are relying on the reversal of existing deductible temporary differences to support the realizability of your deferred tax assets, please disclose that the deferred tax liabilities you are relying on are of the same character and will reverse in both the same period and  jurisdiction as the temporary differences giving rise to the deferred tax.

If you are also relying on tax-planning strategies, please disclose the nature of your tax  planning strategies, how each strategy supports the realization of deferred tax assets, the  amount of the shortfall that each strategy covers, and any uncertainties, risks, or  assumptions related to these tax-planning strategies.

Please provide us with the disclosures you intend to include in future filings. Refer to ASC  740-10-30-16 through 30-25 and Section 501.14 of the Financial Reporting Codification for  guidance.