Initial Letter Date

Form filed

Market Capitalization

05/25/2012

10-Q

$ 7,930 M

We note your disclosure that your consolidated effective tax rate in the first quarter of 2012 was lower than the same period in 2011 primarily due to the reduction in the income tax benefit recognized in connection with the long-lived assets impairment in the [xx] segment due to the estimated lower tax rate for the year, and that the reduction is projected to fully reverse over the balance in 2012. Please explain to us how the reduction in the recognized benefit will reverse over the balance of year.