Untitled Document

Initial Letter Date

Form filed

Market Capitalization

03/23/2012

10-K

$ 4,030 M

You disclose "Based on projected U.S. taxable income and other key operating factors,  the Company concluded in 2010 that it is more likely than not that a significant portion of  the benefit of its deferred tax assets would be realized. As a result, the amount of the valuation allowance related to the deferred tax assets expected to be realized was  reversed, resulting in a net tax benefit in 2010 of $ [xx] million, which was recorded as a  tax benefit in the Company's consolidated statement of operations in 2010." Please  provide us with a detailed analysis to support your conclusion that no additional valuation  allowance was warranted. Your response should address both the positive and negative  evidence you considered in making this determination in accordance with ASC 740.