Untitled Document

Initial Letter Date

Form filed

Market Capitalization

08/30/2012

10-K

$ 1,010 M

We note your statement that you "expect that $[xx] million of valuation allowance related  to certain deferred tax assets of one of our consolidated VIEs may be released in the first  quarter of 2012 when the weight of all available evidence will support full realization of  the deferred tax assets." We also note that you released the valuation allowance in the first quarter of 2012 as predicted. In your critical accounting policies and estimates,  please discuss specific variables and evidence that affected the release of your valuation  allowance. Provide disclosure that allows the reader to analyze your assumptions,  estimates, and judgments. Also, tell us in detail why you did not release the valuation  allowance during the year ended December 31, 2011. Provide us with your proposed  disclosure.

Please provide us with the disclosures you intend to include in future filings. Refer to ASC  740-10-30-16 through 30-25 and Section 501.14 of the Financial Reporting Codification for  guidance.