Untitled Document

Initial Letter Date

Form filed

Market Capitalization

10/18/2013

S-1/A

$ 2,660 M

In note 1 to the table for the components of deferred tax assets and liabilities on page [xx], you state that a full valuation allowance has been provided against the deferred interest tax asset. Given that the deferred interest tax asset in the table is $[xx]at December 31, 2012 and the total valuation allowance for all deferred tax assets at that date is $[xx], please explain how a full valuation allowance has been provided.