The Board of Directors does not believe that any of its brands or its segments carry a significant portion of the Company’s risk profile. The Board of Directors also considered that the compensation across brands and segments is structured similarly, compensation expense is a similar percentage of revenue across brands and segments, and no brands or segments vary significantly from the overall risk and reward structure of the Company.

The Company does not use highly leveraged short-term incentives that drive high risk investments at the expense of long-term Company value.

On the whole, the Company’s employees’ base salaries, the guaranteed portion of total compensation, are an appropriate proportion of total compensation such that the Board of Directors believes it discourages risk taking.

The Company’s stock option plans encourage the employees to achieve performance, not to take excessive risks, and to focus on the long-term interests of the Company due to the fact that these awards vest over time, and are forfeited if the employee does not remain employed at the end of the vesting period. The time-vesting provides an incentive for employees to consider the Company’s long-term interests while still employed at the Company, so that the shares will continue to increase in value.

To the extent employees are eligible to receive incentive compensation, such compensation is based on balanced performance metrics that promote disciplined progress towards longer-term goals and that correlate to the income and risk to the Company.

We are responsible for the adequacy and accuracy of the disclosure in our filing;

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

We may not assert Staff comments as a defense in any proceeding initiated by the Securities and Exchange Commission or any person under the federal securities laws of the United States.