Untitled Document

Initial Letter Date

Form filed

Market Capitalization

08/08/2012

10-Q

$ 607.93 M

Regarding the tax rate reconciliation, explain in proposed disclosure to be included in future periodic reports why the line item "effective tax rate adjustment" results in a reduction of $[xx] million in 2012 as compared to an increase of $[xx] million in 2011. Explain why the effective tax rate in 2012 is a 33.2% benefit on income before tax when your effective tax (benefit) rates in 2011, 2010, and 2009 were (5.6%), 9.5%, and 5.8%.