Untitled Document

Initial Letter Date

Form filed

Market Capitalization

09/11/2012

10-K

$ 2,080 M

We note you have $[xx] million of undistributed earnings of your foreign subsidiaries that you consider to be reinvested indefinitely and for which no taxes have been provided. We further note your disclosures on page [xx] where you state that a significant portion of your cash and cash equivalents balance generally resides in your operations outside of the United States. Tell us the amount of cash and cash equivalents and short term investments that were held outside the United States at year-end. Also, tell us your consideration to disclose such amounts and the amounts, if any that are subject to restriction from and/or additional taxes upon repatriation. We refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350.