Untitled Document

Initial Letter Date

Form filed

Market Capitalization

10/25/2013

10-K

$ 434.92 M

We note from your disclosure on page [xx] that the company has indefinitely reinvested $[xx} million of its undistributed earnings from certain foreign subsidiaries and has not indefinitely reinvested the undistributed earnings from the Chinese subsidiary. Tell us what consideration you gave to disclosing the amount of cash and investments that are currently held outside of the U.S. separately for jurisdictions subject to and not subject to permanent reinvestment and the impact of repatriating the undistributed earnings of foreign subsidiaries. We refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 34-48960.