Untitled Document

Initial Letter Date

Form filed

Market Capitalization

10/25/2013

10-12B

$ 2,460 M

We note your statement that "due to a lack of significant positive evidence" you established a valuation allowance on all U.S federal and certain U.S. state and foreign deferred tax assets. Please explain in greater detail here, and in your Critical Accounting Policies, the negative evidence you evaluated leading you to conclude that an allowance was needed on all U.S. and certain U.S. state and foreign deferred tax assets. Furthermore provide disclosures on how you arrived at the estimate, including the assumptions and estimates used to determine the valuation allowance.