Initial Letter Date |
Form filed |
Market Capitalization |
12/19/2013 |
10-K |
$ 2,710 M |
A significant portion of your cash and cash equivalents at each balance sheet presented in this filing and in the Form 10-Q for the period ended July 31, 2013 is held outside of the United States. In view of this, please disclose the availability of cash outside of the U.S. to fund U.S. operations and obligations and the impact on the liquidity of your U.S. operations by maintaining such a significant amount of cash and cash equivalents outside of the U.S. You should also state here the need to accrue and pay taxes upon the repatriation of undistributed earnings of your non-U.S. entities, along with a statement of your intention not to repatriate such earnings, to the extent true, or your need to access the associated funds. Refer to Item 303(a)(1) of Regulation S-K, and Section IV of Release 33-8350 "Interpretation: Commission Guidance Regarding Management's Discussion and Analysis of Financial Condition and Results of Operations" available on our website at http://www.sec.gov/rules/interp/33-8350.htm for further guidance. |