Untitled Document

Initial Letter Date

Form filed

Market Capitalization

11/25/2013

10-K

$ 4,630 M

We note from page [xx] that at December 30, 2012 you hold a cumulative total of $[xx] million of undistributed earnings in non-U.S. subsidiaries that you plan to reinvest outside the U.S. indefinitely. As we note that your cash and cash equivalents totaled $[xx] million at that date, please tell us the amount of cash and equivalents and liquid investments held by your foreign subsidiaries at December 30, 2012 and quantify the amount that would not be available for use in the U.S. without incurring U.S. taxes.