Untitled Document

Initial Letter Date

Form filed

Market Capitalization

01/18/2012

20-F

$ 904.98 M

As a related matter if you no longer believe you need a valuation allowance  against your deferred tax assets as of December 31, 2009 and you believe you can  reverse the 2008 valuation allowance balance, please provide us with both the  negative and positive evidence you used to support your conclusion.