Untitled Document

Initial Letter Date

Form filed

Market Capitalization

07/03/2012

8-K

$ 1,070 M

We note your disclosure stating you expect that all of the deferred tax asset valuation  allowance will be reversed during the second quarter of 2012, except for the portion that  is expected to offset the taxable income for the third and fourth quarters of 2012. We also note from Note 9 of your Form 10-Q for the quarter ended March 31, 2012 that your  fully reserved deferred tax asset as of March 31, 2012 was $[xx] million and that you had  recorded a full valuation allowance as you did not meet the required threshold of more  likely than not for realizing the benefit of your deferred tax asset. Given your net income  before income taxes was $[xx] million in 2011 and $[xx] million during the quarter ended March 31, 2012, please provide us with the preliminary analysis you performed to determine it would be appropriate to reverse your entire deferred tax asset valuation  allowance during the second quarter of 2012, except for the portion that is expected to  offset the taxable income for the third and fourth quarters of 2012.