Initial Letter Date

Form filed

Market Capitalization

07/02/2012

10-K

$ 426.29 M

We note from page [xx] that during 2010 you adopted a plan of reorganization for tax - planning purposes in order to protect your substantial net operating losses. Please explain to us in more detail the nature of the reorganization, how you accounted for the reorganization and how it impacted your financial statements, including your accounting for your taxes under Topic 740 of the FASB Accounting Standards Codification. Please make sure your response cites the specific accounting literature you considered when accounting for and presenting the referenced transaction.