Untitled Document

Initial Letter Date

Form filed

Market Capitalization

05/03/2012

S-1

$ 1,730 M

We note your statement that you expect to maintain a full valuation allowance on your  net deferred income tax assets until you sustain an appropriate level of profitability that  generates taxable income that would enable you to conclude that it is more likely than not  that a portion of your deferred income tax assets will be realized, However, per the table  on page [xx] you have a valuation allowance of only approximately $[xx]million and net  deferred income tax assets of approximate $[xx]million. Please advise.