Untitled Document

Initial Letter Date

Form filed

Market Capitalization

11/21/2013

10-K

$ 6,360 M

Based on your disclosure on page [xx] it does not appear that you repatriated any foreign earnings during fiscal 2013, though we note the relatively small impact therefrom in the tax rate reconciliation on page [xx]. However, you indicated that you repatriated $[xx] million at year end in the CFO's prepared remarks of the earnings call transcript. Please clarify or reconcile. United States Securities and Exchange Commission December 6, 2013