Adam Phippen

Securities and Exchange Commission

November 21, 2007

Page 2

June 30, 2007 and July 1, 2006, respectively, should no longer be relied upon was based on the two errors described in the Form 8-K (with respect to the overstated depreciation and amortization in connection with our U.K. operations and our material misstatement of comprehensive income). Each of those items is described in the first paragraph of the Form 8-K. In addition, the Company filed the Form 8-K concurrently with the Form 10-Q/A, and included a specific reference to the Form 10-Q/A in the Form 8-K, and in particular to footnote 2, where the nature of the restatement and the circumstances relating to the restatement are further explained. In view of the fact that there is a specific cross-reference to the Form 10-Q/A and the fact that the filings were concurrent, we do not believe an amended Form 8-K is warranted or necessary under the circumstances. We will take your comment regarding form requirements under advisement in connection with any future filings.

In addition, please provide us with a detailed description of your previous accounting treatment and your revised accounting treatment for each of the errors. In regard to the error involving comprehensive income, please provide us with any additional information necessary to completely understand both your previous and revised accounting treatment and tell us the basis in GAAP for your revised accounting treatment.

Response:

Depreciation and amortization error. The error with respect to the depreciation and amortization affected only the statement of cash flows and only occurred in the second quarter of 2007. The Company determined that the error was the result of an unintentional error in the translation of United Kingdom depreciation and amortization in the United Kingdom cash flow worksheet. The cash flow worksheet for the United Kingdom is prepared in GBP and then converted to United States dollars for reporting purposes. The Company erroneously entered the depreciation and amortization number in the worksheet in United States dollars, and then subsequently converted the entire worksheet to United States dollars. As a result of the erroneous entry, the amount of depreciation was approximately doubled for the United Kingdom. In the cash flow worksheet, the offset of the error in depreciation and amortization was forced to purchases of property, plant and equipment, net, resulting in an understatement of that amount and an overstatement of the depreciation and amortization for our U.K. operations. This error had no impact on the consolidated balance sheet as of June 30, 2007, the consolidated statement of operations (including earnings per share) for the thirteen and twenty-six weeks ended June 30, 2007 or the net decrease in cash and cash equivalents reported in the consolidated statement of cash flows as of June 30, 2007. This error was not the result of a misapplication of GAAP, but a calculation error. As such, no revision to the Company’s accounting treatment is necessary in connection with the correction of this error.

Comprehensive income error. In the 2007 second quarter, the Company determined that it had incorrectly recorded a note receivable and related interest due from a foreign subsidiary and subsequent foreign currency translation effects, resulting in understatements of goodwill and accumulated other comprehensive income (“AOCI”), and an overstatement in accounts payable. This incorrect recording of the note receivable and related interest also resulted in the misstatement of