Untitled Document

Initial Letter Date

Form filed

Market Capitalization

02/29/2012

10-K

$ 2,450 M

We note that you recorded an income tax benefit of $[xx] million in fiscal 2011 as a result  of the release of a significant portion of your valuation allowance, as further discussed on  pages [xx] and [xx]. Giving specific consideration to negative evidence such as  cumulative losses in recent years, as well as your discussion of continued economic  uncertainty in the industry, please tell us in further detail why you believe that it is more  likely than not that these deferred tax assets will be realized. We also note that you have  reported a net loss for the period ended December 31, 2011, as part of your response,  please tell us how your actual results for the period compare to the forecasts that appear  to be heavily weighted as part of your conclusion. Refer to the guidance provided in  FASB ASC 740-10-30-5e and 30-17 through 30-23 (formerly paragraphs 17(e) and 20  through 25 of SFAS 109). Please also revise your disclosure here and your critical  accounting policies in MD&A in future filings to more fully explain how you reached  your conclusion and how you weighted both the positive and negative evidence.