Untitled Document

Initial Letter Date

Form filed

Market Capitalization

09/11/2012

10-K

$ 2,080 M

We note that your valuation allowance at both January 31, 2012 and 2011 relates  primarily to foreign net loss carryforwards, the majority of which have indefinite carryforward periods. Considering you have generated pre-tax net income from your  foreign operations for each of the last five fiscal years, tell us and disclose in future  filings how you determined that it is more likely than not that these deferred tax assets will not be realized. In this regard, describe, in reasonable detail, the nature of the  positive and negative evidence that you considered to assess the likelihood of realizing the deferred tax assets. Indicate how the positive and negative evidence was weighted. See ASC 740-10-30-17 through 22 for guidance..