Untitled Document

Initial Letter Date

Form filed

Market Capitalization

06/26/2012

10-K

$ 1,860 M

We note the fluctuations in your effective tax rate for the quarterly periods of 2011 and 2010. Please tell us how you estimated your effective tax rate for each of your interim periods during fiscal 2010 and 2011. Specifically address the reasons for any items excluded from the estimated annual effective tax rate. Finally, provide us with references to the authoritative U.S. GAAP you considered as a basis for determining your interim tax rate estimates.