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1.

We note your disclosures on page 26 related to the increase in your revenues. We further note that there is no indication of how unit volumes and/or changes in selling prices attributed to the increase. Please revise your future filings to separately quantify the effects of volume and pricing changes on your results of operations. Please also revise statements like the “growth in our core business” mentioned in your most recent Form 10-Q to explain clearly the causes underlying the changes you note. Further, when you attribute changes in your margin to shifting product mix, please revise to clarify how that mix has shifted. Refer to Item 303(a)(3)(iii) of Regulation S-K.

2.	We note your disclosures on page 45 that you utilize the Monte Carlo simulation method to fair value complex awards with market-based performance conditions. Please revise your future filings to disclose the significant assumptions utilized in this model and how the underlying assumptions were developed:

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3.

We note that you have recorded $59.4 million of contingent consideration liability related to your 2011 business combinations and classified this contingent consideration as Level 3 in the fair value hierarchy. We further note that you have utilized a discounted cash flow model and similar techniques to value this contingent consideration. Please revise your future filings to disclose the significant assumptions utilized in this model and how the underlying assumptions were developed.

4.	We note your disclosures related to your outstanding litigations, claims, and assertions. Please revise your future filings to disclose the amount accrued, if any, related to these proceedings to the extent that it may be necessary for the financial statements not to be misleading. Please refer to 450-20-50-1 of the FASB Accounting Standards Codification.

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5.

Further to the above, if there is at least a reasonable possibility that a loss exceeding amounts already recognized may have been incurred, in your next periodic filing, please either disclose an estimate (or, if true, state that the estimate is immaterial in lieu of providing quantified amounts) of the additional loss or range of loss, or state that such an estimate cannot be made. Please refer to 450-20-50 of the FASB Accounting Standards Codification.

6.	Please tell us, and revise future filings to describe in more specific detail, how you determined the amounts actually paid pursuant to the cash incentive plan, including which goals were achieved and which were not. It is currently unclear from your

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•	If the level of achievement for that performance goal falls below the “threshold” level, then the executive will not earn any Short-term Comp with respect to that performance goal (absent an exercise of discretion by the Compensation Committee).

•	If the level of achievement for that performance goal is equal to the “threshold,” “target” or “maximum” level, then the executive earns the product obtained by multiplying (i) the “threshold,” “target” or “maximum” percentage, as applicable, times (ii) the executive’s base salary for the relevant six month period times (iii) the weighting assigned to that performance goal.

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If the level of achievement for the performance goal falls in between either the “threshold” and “target” levels or the “target” and “maximum” levels the executive would earn Short-term Comp equal to the Short-term Comp payable at the “threshold” or “target” level, respectively, plus a pro rata amount of the difference between the Short-term Comp payable for that performance goal at, respectively, the “threshold” and “target” levels or the “target” and “maximum” levels.

•	Absent an exercise of discretion by the Compensation Committee, if the level of achievement for the performance goal exceeds the “maximum” level, the executive will only earn the amount payable for achievement at the “maximum” level.

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7.

We note from your disclosure that you have not disclosed the specific targets to be achieved in order for your named executive officers to earn their respective cash incentive payments, and that such targets appear to include financial measures applicable to your last-completed fiscal year. Please disclose those targets in your future filings, as applicable. To the extent you believe that disclosure of such information, on a historical basis, would result in competitive harm such that the information could be excluded under Instruction 4 to Item 402(b) of Regulation S-K, please provide us with a detailed explanation supporting your conclusion. To the extent that it is appropriate to omit specific targets or performance objectives, you are required to provide appropriate disclosure pursuant to Instruction 4 to Item 402(b) of Regulation S-K. Refer also to Question 118.04 of the Regulation S-K Compliance and Disclosure Interpretations available on our website at http://www.sec.gov/divisions/corpfin/guidance/regskinterp. htm. In discussing how difficult or likely it will be to achieve the target levels or other

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Revenue. The “revenue” performance goal is based on the Company’s reported GAAP revenue. Disclosing the revenue performance goal target levels would cause substantial competitive harm to the Company because it would provide the Company’s competitors with insight into the Company’s market growth expectations and acquisition strategy, which they could use, for example, to guide timelines for development of competing products or changing pricing strategy. The Company’s competitors would be able to both predict the areas of growth the Company was targeting and the means by which the Company expected to achieve that growth. For example, if the range of performance target levels for revenue reveal a more aggressive revenue growth rate than the Company’s competitors were predicting and the higher performance goal targets for non-GAAP gross margin also reveal higher than historical margins, the Company’s competitors could discern, in the context of other information available in the market, that the Company was targeting an acquisition or was investing in a new growth area. This could spur the Company’s competitors, who would likely have a working understanding of the new areas for growth in the Company’s industry, but who otherwise might not have intended to act, to increase their efforts to capture market share or seize a first-mover advantage or who are aware of the strategic acquisition opportunities in the industry, to pursue an opportunistic acquisition or advance their review of potential targets.

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•	Non-GAAP Operating Margin and Non-GAAP Gross Margin. Disclosure of either non-GAAP operating margin or gross margin performance goals could cause the Company to suffer substantial competitive harm because of the product development and pricing flexibility information that it would provide to competitors, customers and suppliers.

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Customer Satisfaction. The Customer Satisfaction performance goal is based on the Company’s actual performance with respect to both the timeliness of shipments to customers and reduction in returned products over a specified period of time. The Company does not disclose customer satisfaction metrics externally under any other circumstances. The Company would suffer substantial competitive harm by disclosing the targets and results for this performance goal because of the leverage it would give customers in contract and pricing negotiations and the advantage it would give competitors in trying to attract existing and win new customers. By disclosing both the Company’s range of performance goal targets and actual performance in customer service, the Company’s competitors could tailor their customer proposals and gain an advantage at securing new customer business or attracting existing customer business by promising better service levels or better pricing and similar service levels. Further, to the extent that the customer service experience of an individual customer falls below the overall level of customer satisfaction performance, the stated performance goal targets are below the expectations of prospective customers or the range of performance goals that would trigger satisfactory performance by the Company is deemed by a customer to be unduly broad, existing customers would demand pricing concessions or additional service enhancements at no cost to them and new customers may be less inclined to engage the Company because of a negative stigma attached to poor customer service.

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Cash. The Cash performance goal is based on the Company’s cash generated during each six month period as measured by the number of times that inventory is turned over during the period. The Company would suffer a substantial competitive harm if it was required to disclose the targets and actual results for this performance goal because of the ability of the Company’s competitors to use such information to gain market share by managing their own inventory in a way to ensure greater product availability and decreased order fulfillment time as compared to those targeted by the Company.

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Design Wins. The Design Win performance goal is based on the total number and the quality or difficulty of achievement of a pre-established list of design/installation projects awarded to or contracted by the Company. To establish the performance goal targets, the Compensation Committee establishes a list of design projects that will be targeted. In order for any disclosure of the performance goal to be meaningful, the Company would need to disclose the names of the customers and the design projects being targeted and the degree of difficulty assigned to that project. The Company does not otherwise disclose this information, is not required to disclose this information and in many cases is contractually prohibited from disclosing this information. Clearly, the Company would suffer substantial competitive harm by disclose the names of its customer and design project targets and the priority that the Company is placing on securing each such project, even on a historical basis, because the Company’s competitors compete for the same

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Units Shipped. The Units Shipped performance goal is based on the aggregate number of certain specified products shipped by the Company over a specified period of time. The Company would suffer substantial competitive harm if it was required to disclose the targets and actual results for this performance goal because of the insight into the Company’s sales and marketing plans it would provide to the Company’s competitors, thereby allowing them to better deploy their own sales and marketing resources to capture market share. If the Company disclosed its actual units shipped, broken down by product category or type, when reviewed in the context of the Company’s actual revenue, non-GAAP gross margin and non-GAAP operating margin and other information available to the competitor in the marketplace, a competitor could determine whether the Company was focused on high margin/low volume business or the opposite and could more effectively deploy resources to compete in areas where the competitor has an advantage and could gain market share. It could further provide competitors with insight into the Company’s pricing strategies when viewed in connection with other information available in the market and gained privately by the competitor. When combined with the Company’s actual inventory turnover, a competitor could understand further the Company’s supply chain challenges and use that information to better position itself with customers as a more reliable source of product. The breadth of the range of performance goal targets and the Company’s actual performance against that range, when combined with other information available to the competitor, would allow the competitor to know if a new product was successfully launched, a product gained

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•	“The target financial performance metrics established by the Compensation Committee under the Incentive Plan are based on our historical operating results and growth rates as well as our expected future results, and are designed to require significant effort and operational success on the part of our executives and the Company.” (Page 10)

•	“The maximum financial performance metrics established by the Committee have historically been difficult to achieve and are designed to represent outstanding performance that the Committee believes should be rewarded.” (Page 10)

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The “target” level performance goals established by the Compensation Committee are based on the Company’s historical operating results and growth rates as well as the Company’s expected future results, and are designed to require significant effort and operational success on the part of the Company’s executives and the Company. The “maximum” financial performance metrics established by the Committee have historically been difficult to achieve and are designed to represent outstanding performance that the Committee believes should be rewarded. Financial performance metric goals are set with the expectation that the “target” level will be higher than the consensus analyst estimates for the Company. The “target” level for non-financial performance goals are set with the expectation that actual results in the prior six month period will be exceeded. With respect to each performance goal for the first six months of fiscal 2011, the “threshold” level performance goals were higher than the Company’s actual results for the previous six month period and the “maximum” level performance goals for the same six month period in 2010, except for Customer Satisfaction, where the “threshold” level performance was higher than the “target” level of performance and except for the Cash performance target, which was approximately the same as in the same six month period in 2010. With respect to each comparable performance goal for the second six months of fiscal 2011, the “threshold” level performance goals were higher than the “maximum” level performance goals for the same six month period in 2010, except for Customer Satisfaction, where the “threshold” level performance goal was higher than the “target” level of performance.

8.	Please tell us, and revise future filings to explain, the reasons underlying the changes in your sources and uses of cash. For example, you attribute decreased cash from investing

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•	the Company is responsible for the adequacy and accuracy of the disclosure in its filings;

•	Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•	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.