Untitled Document

Initial Letter Date

Form filed

Market Capitalization

02/24/2012

10-K

$ 1,730 M

Please address the following:  Reconcile for us the $[xx] of excess tax benefits that you state was credited to  additional paid in capital during the year ended June 30, 2011 to where that amount is  included in your consolidated statements of stockholders' equity and show us the journal  entry you made to record this amount.

Refer to the $[xx] stock-based compensation tax benefits credited to additional paid in capital in your statements of stockholders' equity during the year ended June 30,  2011 and the same amounts reflected as an adjustment reducing net cash provided by  operating activities and increasing net cash provided by financing activities in your  consolidated statement of cash flows. Reconcile this benefit to the table of current and  deferred income tax expense and to the table that reconciles your income tax expense to  the statutory federal income tax rate. Further, tell us how reflecting these line items in  your statement of cash flows complies with GAAP.

Reconcile the $[xx] change in valuation allowance during the year ended June 30, 2011 reflected in your table of current and deferred income tax expense to the 2.1%  change in valuation allowance reflected in the table that reconciles your income tax  expense to the statutory federal income tax rate.

Tell us the factors that determined whether net operating losses are reflected as deferred  income tax assets versus those that are not and how your accounting complies with GAAP.

Refer to your discussion of income tax expense on page [xx] in MD&A under results of  operations for the years ended June 30, 2011 and 2010. Provide us support for the  statement that the income tax benefit of $[xx] million in 2010 consisted of the reversal in  full of your valuation allowance when your valuation allowance at June 30, 2010 was  $[xx]. Also provide us support for your statement that 2011 contained no benefit  from the reversal of previous valuation allowances given that you show $[xx]  change in valuation allowance during the year ended June 30, 2011 reflected in your table  of current and deferred income tax expense. Further, tell us why your discussion of  income tax expense for 2011 does not address the $[xx] stock-based compensation  tax benefits shown as a reduction to adjust net income in your statement of cash flows. If  necessary after reconsidering statements you have made in this discussion, provide us  revised proposed disclosure of the discussion of income tax expense for 2011 and 2010 to  be included in future periodic reports.