Untitled Document

Initial Letter Date

Form filed

Market Capitalization

11/27/2013

10-K

$ 861.51 M

We note that your reconciliation of the effective tax rate includes a line item with the caption "Foreign dividends". Please tell us whether or not this line item represents repatriation of foreign earnings during the periods presented. If it does, please tell us the nature, amount, timing and special circumstances surrounding each repatriation and tell us how you evaluated the criteria for the exception to recognition of a deferred tax liability in accordance with ASC 740‑30‑25‑17 and 18 for undistributed earnings that are intended to be indefinitely reinvested. Please also describe the type of evidence that sufficiently demonstrates that remittance of earnings will be postponed indefinitely as disclosed on page [xx].