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. |