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1.
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The
EDGAR version of the audit report on your financial statements is not
signed. Please amend Item 8 of this Form 10-K to include a
signed copy of the audit report. Refer to Rule 2-02(a) of
Regulation S-X.
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2.
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We
note that you present a line item entitled “net payments on long-term
borrowings, including capital lease obligations” within your financing
activity section of your statement of cash flows. Please review
future filings to disclose these borrowings and repayments of your
long-term borrowings, including capital lease payments, on a gross basis
within your statement of cash flows or alternatively tell us why your
presentation is appropriate. Refer to paragraphs 11 and 19 of
SFAS 95.
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3.
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You
state that you recognize interest accrued on unrecognized tax benefits as
well as interest received from favorable tax settlements within general
and administrative expenses. Please tell us how your policy
complies with paragraph 19 of FIN 48, or alternatively review future
filings as appropriate to comply with paragraph 19 of FIN
48.
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4.
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Please
amend the Form 10-K to include the disclosures required by Item 307 of
Regulation S-K.
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The
Company is responsible for the adequacy and accuracy of the disclosure in
the filings;
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Staff
comments or changes to disclosure in response to staff comments in the
filings reviewed by the staff do not foreclose the Commission from taking
any action with respect to the filing;
and
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The
Company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
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