1.	We note the proposed disclosure provided in response to prior comment 1. Please revise your proposed disclosure to also discuss why the cash held outside the United States would not be subject to federal taxation if returned to the United States.

---

2.

We note your response to prior comments 2 and 3. It is unclear to us whether there was a change in the function or underlying activities of the global services and support organization or the network build-out and support group such that a change in classification was warranted. Please describe the services being provided under each of these groups in 2012 and 2013 and tell us whether the underlying services provided by these groups changed between 2012 and 2013.

•	To the extent that there was not a change in function or a change in the underlying activities, tell us how you concluded that the presentation in financial statements issued for periods prior to 2013 was appropriate such that you did not previously classify these expenses as cost of revenue.

•	To the extent that there was a change in function or a change in the underlying activities, provide additional details regarding how and when the functions and activities changed and tell us how you concluded that the reclassification of these expenses for periods prior to 2013 was appropriate in your 2013 financial statements.

3.

Additionally, it remains unclear to us how you concluded that a change in the way you analyze your business would result in the reclassification of expenses. As cost of revenues represent the collective costs of deriving revenue, please tell us how you concluded that excluding the costs of services and support and network build-out and support cost of revenues in your financial statements for periods prior to 2013 was appropriate and did not contain an error.

---

---

•	The correction of the expense classification has no impact on our major statement of operations line items: revenues, total costs and operating expenses, income from operations, net income or net income per share; our cash flows; or on any balance sheet line item. We do not present gross margin as a line item in our consolidated statement of operations.

•

The correction of the expense classification does not impact results in order to meet or exceed investors' expectations. We presented the correction at our annual investor summit on March 11, 2013, and since that time have not received any questions from investors on the matter. In fact, analysts issued reports shortly after the annual investor summit commenting on the correction and noted it did not impact operational performance, financial position or cash flows.

•

We provide GAAP and non-GAAP metrics related to gross margin in our quarterly conference calls, including guidance on these metrics. These metrics include cost of revenues and were the only metrics impacted by the correction of the expense classification. However, the overall historical trends in these metrics were not impacted. Further, to prevent any misunderstanding among investors, subsequent to the correction, we revised the prior period metrics on our website, incorporated the changes in the guidance we provided on our public investor calls and explained the impact of the correction at our investor summit.

•	Analyst reports indicate that our market valuation is driven by a combination of revenue growth, which drives profitability, earnings as measured by a net income per share metric or EBITDA. The individual analysts use different combinations, but revenues and profitability are the key valuation drivers. The correction of the expense classification does not impact revenues or profitability.

•

In discussing our guidance on public investor calls, in addition to other measures, we have provided information regarding our future outlook with respect to improved gross margins due to expected continued declines in some of our costs of revenues. Although the correction of the expense classification increases our total cost of revenues, the change does not impact our overall assessment of expected future gross margin expansion.

•	The correction of the expense classification does not materially impact any prior reported trends in the individual expense line items impacted, including non-GAAP metrics associated with cost of revenues.

•	The correction of the expense classification does not impact compliance with regulatory requirements or any contractual requirements.

•	The correction of the expense classification does not have any impact on past or current executive or employee compensation.

---

---

---

---

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

•	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

•	We 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.