701 N. Lilac Drive
P.O. Box 1452
Minneapolis, MN
55440-1452
T: Direct: 763.540.1204
F: Direct: 763.513.1811
BY EDGAR
October 5, 2016
Mr. Terence O’Brien, Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
Form 10-K for the Year Ended December 31, 2015
Filed February 29, 2016
Form 10-Q for the Period Ended June 30, 2016
Filed July 28, 2016
File No. 1-16191
Dear Mr. O’Brien:
The purpose of this letter is to confirm our understanding, based on our phone conversation with your office on October 5, 2016, that the Securities and Exchange Commission has taken no exception to our request for additional time to respond to the comments identified in your letter dated September 21, 2016. As discussed, our response will be provided on or before October 20, 2016.
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| | Very truly yours, |
| | |
| | /s/ Thomas Paulson |
| | Thomas Paulson |
| | Senior Vice President and Chief Financial Officer |