Untitled Document

Initial Letter Date

Form filed

Market Capitalization

07/31/2012

40-F

$ 8,060 M

We note you disclose that $[xx] million of your $[xx] million balance of cash and cash equivalents were held in operating entities in China and Turkey as of December 31, 2011.

We also note you have an established policy and history for paying dividends and substantially all of your revenue and income from operations are generated from foreign sources. Considering the items noted above and your disclosure on page [xx] of your financial statements that you intend to indefinitely reinvest the $[xx] billion in unremitted earnings of foreign subsidiaries for the foreseeable future, please expand your disclosure to address your plans for future sources of cash necessary to pay for dividends, exploration and evaluation expenditures, development costs and capital expenditures in other jurisdictions, and administrative and corporate operating expenses.