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We note that you use Adjusted EPS, Relative TSR, and Relative Stock Price Growth as performance metrics for compensation. In future filings, to the extent you continue to use performance metrics that are impacted by your stock repurchases, please discuss if and how the stock repurchases affected the manner in which you set the relevant targets and determined whether such targets were met.

The Company respectfully acknowledges the Staff’s comment and notes that stock repurchases are not excluded from the Company’s performance metrics and that the Compensation Committee evaluates planned stock repurchases when setting performance metric

ALKHOBAR AMSTERDAM ATLANTA BEIJING BOSTON BRISBANE BRUSSELS CHICAGO CLEVELAND COLUMBUS DALLAS

DETROIT DUBAI DÜSSELDORF FRANKFURT HONG KONG HOUSTON IRVINE LONDON LOS ANGELES MADRID

MELBOURNE MEXICO CITY MIAMI MILAN MINNEAPOLIS MOSCOW MUNICH NEW YORK PARIS PERTH PITTSBURGH RIYADH

SAN DIEGO SAN FRANCISCO SÃO PAULO SHANGHAI SILICON VALLEY

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SINGAPORE SYDNEY TAIPEI TOKYO WASHINGTON targets. In future filings, to the extent applicable, the Company will provide additional disclosure regarding how stock repurchases affected the manner in which the Compensation Committee set the relevant performance metric targets and determined whether such targets were satisfied.

In connection with your comments, we acknowledge that the Company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the Staff.

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