Untitled Document

Initial Letter Date

Form filed

Market Capitalization

07/05/2012

10-K

$ 6,960 M

Please tell us your consideration of disclosing the amount of income tax expense or benefit allocated to each component of comprehensive income, including reclassifications adjustments. Refer to ASC 220-10-45-12. Please also tell us how you determine the amounts of income tax expense or benefit allocated to items of other comprehensive income and why your allocation policy complies with ASC 740-20-45-14