Untitled Document

Initial Letter Date

Form filed

Market Capitalization

03/30/2012

10-K

$ 4,200 M

We note from page [xx] that during 2011, $[xx] million of your deferred tax valuation  allowance was released. Please tell us the nature of the circumstances that resulted in the  release of the valuation allowance and the positive evidence which supported the basis  for your conclusions. Your response should state the amounts released related to the  foreign subsidiaries, restructuring and other items. We may have further comment upon  receipt of your response.