Untitled Document

Initial Letter Date

Form filed

Market Capitalization

08/29/2013

S-1

$ 2,660 M

Please clarify for us and in your disclosure how income tax expense was incurred for the six months ended June 30, 2013 despite a reported loss for the period and a reduction in the deferred tax for expense for this period associated with indefinite-lived assets referred to here. In particular, clarify how the expected utilization of net operating losses resulting from the reorganization gain that occurred in the prior year contributed to the increase in the effective tax rate for the six months ended 2013 compared to the six months ended 2012.