Untitled Document

Initial Letter Date

Form filed

Market Capitalization

12/13/2013

20-F

$ 806.08 M

We note your disclosure that ASC 718 prohibits recognition of a deferred tax asset for excess tax benefits due to stock option exercises that have not yet been realized through a reduction in income tax payable, and that such unrecognized deferred tax benefits will be accounted for as a credit to additional paid-in-capital, if and when realized. We also note your disclosure that the net change in valuation allowance primarily relates to stock option benefits and was accounted for as a credit to additional paid-in-capital. Please clarify your accounting for excess tax benefits and whether you have recognized any deferred tax assets relating to these benefits. We further note that your income tax rate reconciliation includes a benefit of $[xx] million relating to "utilization of tax losses and deferred taxes for which a valuation allowance was provided," which appears to equal the change in valuation allowance. Please clarify the source of the income tax benefits realized, considering your disclosure that the change in valuation allowance primarily relates to stock option benefits which were accounted for as a credit to additional paid in capital. Tell us what consideration you gave to clarifying your disclosures.