Reference is made to the Registration Statement on Form S-1 (File No. 333-177207) filed with the Commission on October 7, 2011 (the “October Registration Statement”) and amended on November 8, 2011 (the “October Registration Statement Amendment” and, together with the October Registration Statement, the “Registration Statements”).
Pursuant to Rule 477 promulgated under the Securities Act of 1933, as amended (the “Securities Act”), the Company is applying for the immediate withdrawal of the Registration Statements and all amendments and exhibits thereto as the Company has determined that registration of the securities under the Registration Statements is no longer in the best interests of the Company. The Company has not sold any shares in connection with the Registration Statements. The Company may in the future rely on Rule 155(c) for subsequent private offerings of its securities and utilize the “Safe Harbor” from integration provided by Rule 155 promulgated under the Securities Act.