Untitled Document

Initial Letter Date

Form filed

Market Capitalization

02/03/2012

10-K

$ 699.46 M

We note that you separately disclose excess tax benefit from stock options exercised in  the cash flows from financing activities section. Please tell us whether you have  classified the corresponding cash outflow within the cash flows from operating activities  section and how you considered separately disclosing this amount pursuant to ASC 230-10-45-17(c). Additionally, please clarify whether other types of equity awards, such as  RSUs, impact the amount of excess tax benefit presented.