Untitled Document

Initial Letter Date

Form filed

Market Capitalization

12/04/2013

10-K

$ 413.08 M

We note your disclosure on page [xx] that you have not provided for federal income taxes applicable to the undistributed earnings of your foreign subsidiaries as you consider these earnings to be indefinitely reinvested. Please explain or revise to disclose: the amount of cash and short term investments held by your foreign subsidiaries and a statement that these funds are not readily available to the U.S. parent company; a statement that you would need to accrue and pay taxes if repatriated; and a statement that you do not intend to repatriate the funds. Additionally, please revise to include qualitative disclosure of the impact, if any, of the decision to indefinitely reinvest earnings in foreign tax jurisdictions on your liquidity and capital resources, such as the payment of dividends or the satisfaction of potential future material domestic obligations. Please ensure that your financial statement footnotes provide all disclosures required by ASC 740-30-50-2.