Untitled Document

Initial Letter Date

Form filed

Market Capitalization

08/16/2012

10-K

Private

Given your recurring losses before income tax (expense) benefit, please discuss the nature of  the U.S. deferred tax assets which have not been offset by a valuation allowance and how  you determined that these would be realized. Please also address the following:  Please expand your discussion of the nature of the positive and negative evidence that  you considered, how that evidence was weighted, and how that evidence led you to  determine it was not appropriate to record a valuation allowance on the remaining  deferred income tax assets;  Please disclose the amount of pre-tax income that you need to generate to realize the  deferred tax assets;  Please include an explanation of the anticipated future trends included in your projections  of future taxable income; and  Please disclose that the deferred tax liabilities you are relying on in your assessment of  the realizability of your deferred tax assets will reverse in the same period and  jurisdiction and are of the same character as the temporary differences giving rise to the  deferred tax assets.

Please show us in your supplemental response what the revisions in future filings will look  like.