Securities and Exchange Commission
September 24, 2007
Page 2

General

1.

We note you have a confidential treatment request that is outstanding.  The request will need to be granted prior to the effectiveness of this registration statement.

In response to the Staff’s comment, the Company has amended its confidential treatment request to the Commission.  We subsequently we received a telephone call from John Fieldsend of the Staff in which he indicated that the Staff had no further questions or comments to the confidential treatment request and that the request was granted by the Commission.

2.

We note the registration statement covers a primary offering and a secondary offering. Please revise throughout the filing, including in the registration fee table, to specify the dollar amount for each offering and the number of shares for the secondary offering.

In response to the Staff’s comment, the Company has revised the registration fee table to reflect the fact that the Registration Statement covers both a primary offering and a secondary offering.

Selling Securityholders, page 8

3.

Please provide the information required by Item 507 of Regulation S-K in a pre-effective amendment.  You do not appear to be eligible to provide this information in prospectus supplements or post-effect amendments because it appears you do not satisfy the conditions of Rule 430B(b).

In response to the Staff’s comment, the Company has included the information required by Item 507 of Regulation S-K in the Selling Securityholder section of the Registration Statement.

* * *

The Company would be grateful if the Staff would provide any comments to the revised Registration Statement at its earliest convenience so that the Company may provide any additional responses required.