Initial Letter Date |
Form filed |
Market Capitalization |
10/10/2013 |
S-1 |
$ 21,740 M |
Please tell us the nature of the foreign deferred tax assets that resulted in an additional valuation allowance during 2012. Your response should address when the related foreign deferred tax assets were initially recorded. To the extent the related foreign deferred tax assets existed as of December 31, 2011, please tell us what changed during 2012 that resulted in a need for a valuation allowance. |