Untitled Document

Initial Letter Date

Form filed

Market Capitalization

12/31/2013

10-K

$ 1,290 M

We note your disclosures on page [xx] that you have $[xx] million of undistributed earnings as of December 31, 2012 related to your foreign subsidiaries and that you intend to permanently reinvest these earnings within your foreign subsidiaries in China, South Korea, Japan, Malaysia, Singapore and Taiwan. We also note on page [xx] that you have $[xx] million of cash and cash equivalents outstanding as of December 31, 2012. To the extent cash related to undistributed earnings could be considered material to an understanding of your liquidity and capital resources in future periods, please revise your future filings to disclose the cash and investment amounts held by your foreign subsidiaries that would not be available for use without you incurring income taxes thereon. Please further provide a discussion of any known trends, demands or uncertainties as a result of this policy that are reasonably likely to have a material effect on the business as a whole or that may be relevant to your financial flexibility. Refer to Item 303(a)(1) of Regulation S-K.