Untitled Document

Initial Letter Date

Form filed

Market Capitalization

 

08/01/2012

 

10-K

 

$ 819.86 M

We note your disclosure on page [xx] states that you "have removed your election to permanently reinvest foreign earnings for 2011, 2010 and 2009." We also understand that you may have repatriated some of these earnings in order to fund the redemption of the 1.75% convertible senior notes and the share repurchase in 2011. Please confirm whether our understanding is correct and clarify why you have not recorded deferred tax liabilities in 2011 related to these undistributed foreign earnings to comply with FASB ASC paragraphs 740-30-25-17 through 19.