Untitled Document

Initial Letter Date

Form filed

Market Capitalization

10/03/2012

S-1/A

$ 1,240 M

We read your disclosure on page [xx] where you state, "[W]e continue to assess the  need for a valuation allowance and any changes in our assessment could result in a  material impact to income tax expense." Explain to us and disclose in further detail  why you have recorded a full valuation allowance against your US and Shanghai net  deferred tax assets. Further, please expand your Management's Discussion and  Analysis of Financial Condition and Results of Operations to disclose the general  risks that lead to the conclusion that it was more likely than not that the majority of  your deferred tax benefits would not be realized as of July 28, 2012. Refer to ASC  740-10-30-5 and the requirement in Item 303(a)(3) of Regulation S-K to disclose  events and uncertainties that management reasonably expects will have a material  impact on results of operations. If you anticipate that it is at least reasonably possible  that a change in the valuation adjustment will occur in the near term, your financial  statements must disclose this possibility. Refer to ASC 275-10-50-6 through 50-15.