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Division of Corporation Finance
2010 No-Action Letters Issued Under Exchange Act Rule 14a-8

Important Note: This page contains no-action letters the Division of Corporation Finance issued under Exchange Act Rule 14a-8 during calendar year 2010. Where we take written action on correspondence following the date of a no-action letter, you may find the later materials in the link presented below the citation to the original no-action letter. Pursuant to the Federal Information Security Management Act of 2002 and OMB Memorandum M-07-16, we have removed, to the maximum extent practicable, personally identifiable information from the materials.

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Alphabetical Listing
Chronological Listing

Alphabetical Listing

# A B C D E F G H I J K L M N O P Q R S T U V W XYZ

A

Abbott Laboratories, December 22, 2010
Abbott Laboratories, January 27, 2010
Abbott Laboratories, January 12, 2010
Abercrombie & Fitch Co., April 12, 2010
Aetna Inc., January 25, 2010
AFLAC Incorporated, December 22, 2010
Alaska Air Group, Inc., March 8, 2010
Allegheny Technologies Incorporated, March 1, 2010
Allegheny Energy, Inc., February 12, 2010
Allergan, Inc., February 22, 2010
The Allstate Corporation, March 3, 2010
The Allstate Corporation, February 5, 2010
The Allstate Corporation, February 24, 2010
Alpha Natural Resources, Inc., February 1, 2010
Altria Group, Inc., April 2, 2010
Altria Group, Inc., April 20, 2010
Amazon.com, Inc., March 22, 2010
Amazon.com, Inc., April 7, 2010
American Express Company, February 19, 2010
American Express Company, February 2, 2010
AmerisourceBergen Corporation, November 15, 2010
AmerisourceBergen Corporation, December 8, 2010
AMR Corporation, February 12, 2010
AMR Corporation, February 12, 2010
Apache Corporation (no response)
Archer-Daniels-Midland Company, August 18, 2010
AT&T Inc., December 22, 2010
AT&T Inc., December 16, 2010
AT&T Inc., March 2, 2010
AT&T Inc., March 1, 2010
AT&T Inc., March 12, 2010
AT&T Inc., February 23, 2010
AT&T Inc., February 16, 2010
AT&T Inc., March 2, 2010
AT&T Inc., February 12, 2010
AT&T Inc., January 4, 2010
Avery Dennison Group, December 20, 2010

B

Ball Corporation, January 25, 2010
Ball Corporation, March 12, 2010
Bank of America Corporation, December 15, 2010
Bank of America Corporation, March 3, 2010
Bank of America Corporation, March 2, 2010
Bank of America Corporation, March 1, 2010
Bank of America Corporation, February 26, 2010
Bank of America Corporation, February 24, 2010
Bank of America Corporation, February 24, 2010
Bank of America Corporation, February 22, 2010
Bank of America Corporation, February 16, 2010
Bank of America Corporation, February 1, 2010
Bank of America, January 29, 2010
Bank of America Corporation, March 8, 2010
Bank of America Corporation, January 13, 2010
Bank of America Corporation, February 11, 2010
Bank Of America Corporation, January 6, 2010
Becton, Dickinson & Company, November 1, 2010
BioSpecifics Technologies Corp., April 5, 2010
The Boeing Company, February 6, 2010
The Boeing Company, February 5, 2010
The Boeing Company, February 3, 2010
The Boeing Company, February 1, 2010
The Boeing Company, January 29, 2010
The Boeing Company, January 27, 2010
Bristol-Myers Squibb Company, January 28, 2010
Bristol-Myers Squibb Company, January 7, 2010
Brocade Communications Systems, Inc., January 15, 2010
Brocade Communications Systems, Inc., January 14, 2010

C

Cabot Oil & Gas Corporation, January 28, 2010
Casade Financial Corporation, March 4, 2010
Casade Financial Corporation, March 4, 2010
Cascade Financial Corporation, February 25, 2010
Cascade Financial Corporation, February 22, 2010
Cascade Financial Corporation, February 22, 2010
Cascade Financial Corporation, February 22, 2010
Caterpillar Inc., March 31, 2010
Caterpillar Inc., March 30, 2010
CB Richard Ellis Group, Inc., April 15, 2010
Celgene Corporation, April 5, 2010
Central Federal Corporation, March 8, 2010
Central Pacific Financial Corp., January 20, 2010
The Charles Schwab Corporation, February 19, 2010
The Charles Schwab Corporation, January 19, 2010
Chesapeake Energy Corporation, April 13, 2010
Chesapeake Energy Corporation, April 2, 2010
Chevron Corporation, April 1, 2010
Chevron Corporation, February 6, 2010
Chevron Corporation, March 1, 2010
CIGNA Corp., December 22, 2010
CIGNA Corporation, January 26, 2010
Cisco Systems, Inc., October 18, 2010
Citigroup Inc., February 23, 2010
Citigroup Inc., February 22, 2010
Citigroup Inc., January 27, 2010
Citigroup Inc., January 21, 2010
Citigroup Inc., January 19, 2010
Citigroup Inc., January 4, 2010
Cleco Corporation, January 29, 2010
Coach, Inc., August 19, 2010
Coachmen Industries, Inc., January 14, 2010
CoBiz Financial Inc., March 22, 2010
The Coca-Cola Company, December 29, 2010
The Coca-Cola Company, February 17, 2010
The Coca-Cola Company, March 3, 2010
Comcast Corporation, March 18, 2010
Comcast Corporation, March 17, 2010
Comcast Corporation, March 9, 2010
Comcast Corporation, March 5, 2010
Comcast Corporation, February 22, 2010
Comcast Corporation, March 23, 2010
Comcast Corporation, January 29, 2010
Commonwealth Biotechtechnologies, Inc., December 28, 2010
Continental Airlines, Inc., March 22, 2010
Continental Airlines, Inc., February 22, 2010
CSX Corporation, January 5, 2010
CVS Caremark Corporation, March 9, 2010
CVS Caremark Corporation, March 17, 2010
CVS Caremark Corporation, February 25, 2010
CVS Caremark Corporation, January 5, 2010
CVS CaremarkCorporation, January 26, 2010

D

D.R. Horton, Inc., September 30, 2010
Danaher Corporation, January 19, 2010
DaVita Inc., March 31, 2010
Del Monte Foods Company, June 3, 2010
Devon Energy Corporation, April 20, 2010
Dominion Resources, Inc., November 16, 2010
Dominion Resources, Inc., January 19, 2010
Dominion Resources, Inc., March 29, 2010
The Dow Chemical Company, January 27, 2010

E

Eastman Chemical Company, January 6, 2010
Edison International, December 23, 2010
E.I. du Pont de Nemours and Company, February 16, 2010
E. I. DuPont de Nemours and Company, February 16, 2010
E.I. du Pont de Nemours and Company, March 16, 2010
E.I. du Pont de Nemours and Company, February 1, 2010
EMC Corporation, February 26, 2010
EMC Corporation, March 10, 2010
Energen Corporation, February 2, 2010
Ensco International plc, March 18, 2010
Entergy Corporation, January 12, 2010
Entergy Corporation, March 16, 2010
EOG Resources, Inc., February 3, 2010
EOG Resources, Inc., January 11, 2010
EQT Corporation, January 11, 2010
Exelon Corporation, February 26, 2010
Express Scripts Inc., January 28, 2010
Exxon Mobil Corporation, November 16, 2010
Exxon Mobil Corporation, March 19, 2010
Exxon Mobil Corporation, March 19, 2010
Exxon Mobil Corporation, February 16, 2010
Exxon Mobil Corporation, February 16, 2010
Exxon Mobil Corporation, March 23, 2010
Exxon Mobil Corporation, February 12, 2010
Exxon Mobil Corporation, January 27, 2010
Exxon Mobil Corporation, January 21, 2010
Exxon Mobil Corporation, March 23, 2010

F

The First Bancorp, Inc., February 25, 2010
First Mariner Bancorp, January 8, 2010
First Mariner Bancorp, March 12, 2010
Fluor Corporation, January 11, 2010
Ford Motor Company, March 12, 2010
Ford Motor Company, March 1, 2010
Fortune Brands, Inc., December 16, 2010
Fortune Brands, Inc., January 6, 2010
Freeport-McMoRan Copper & Gold Inc., March 4, 2010
Frontier Communications Corporation, January 26, 2010
Frontier Communications Corporation, January 25, 2010

G

Gannett Co., Inc. , January 7, 2010
General Dynamics Corporation, January 27, 2010
General Electric Company, December 28, 2010
General Electric Company, December 21, 2010
General Electric Company, October 7, 2010
General Electric Company, January 23, 2010
General Mills, Inc., July 2, 2010
Genzyme Corporation, March 1, 2010
Gilead Sciences, Inc., February 19, 2010
GlobalOptions Group, Inc., November 9, 2010
The Goldman Sachs Group, Inc., March 25, 2010
Goldman Sachs Group, Inc., March 12, 2010
The Goldman Sachs Group, Inc., March 11, 2010
The Goldman Sachs Group, Inc., March 9, 2010
Goldman Sachs Group, Inc., March 8, 2010
The Goldman Sachs Group, Inc., February 12, 2010
The Goldman Sachs Group, Inc., February 12, 2010
Goldman Sachs Group, February 3, 2010
Goldman Sachs Group, Inc., February 22, 2010
Google, Inc., January 7, 2010
Great Plains Energy Incorporated, June 17, 2010
Great Plains Energy Incorporated, April 1, 2010
Great Plains Energy Incorporated, February 4, 2010

H

The Hain Celestial Group, Inc., September 16, 2010
The Hain Celestial Group, Inc., October 6, 2010
Halliburton Company, February 12, 2010
Halliburton Company, March 19, 2010
Halliburton Company, February 12, 2010
Halliburton Company, March 19, 2010
Halliburton Company, January 21, 2010
Henry Schein, Inc., February 19, 2010
Hewlett-Packard Company, December 7, 2010
Hewlett Packard Company, July 28, 2010
The Home Depot, Inc., March 12, 2010
Honeywell International Inc., February 18, 2010
Honeywell International Inc., January 19, 2010
Honeywell International Inc., January 4, 2010
Honeywell International Inc., January 26, 2010

I

International Business Machines Corporation, December 28, 2010
International Business Machines Corporation, December 21, 2010
IDACORP Inc., March 4, 2010
Intel Corporation, March 12, 2010
Intel Corporation, March 8, 2010
Intel Corporation, February 3, 2010
InterDigital, Inc., March 31, 2010
InterDigital, Inc., March 11, 2010
International Business Machines Corporation, February 22, 2010
International Business Machines Corporation, March 24, 2010
International Business Machines Corporation, January 22, 2010
International Business Machines Corporation, January 13, 2010
International Business Machines Corporation, January 7, 2010
International Business Machines Corporation, February 22, 2010
International Business Machines Corporation, January 4, 2010
International Paper Company, March 11, 2010
International Paper Company, January 28, 2010

J

Jack in the Box Inc., November 12, 2010
Johnson & Johnson, February 22, 2010
Johnson & Johnson, January 13, 2010
JPMorgan Chase & Co., March 19, 2010
JPMorgan Chase & Co., March 16, 2010
JPMorgan Chase & Co., March 12, 2010
JPMorgan Chase & Co., March 8, 2010
JPMorgan Chase & Co., March 5, 2010
JPMorgan Chase & Co., March 26, 2010
JPMorgan Chase & Co., March 5, 2010
JPMorgan Chase & Co., March 5, 2010
JPMorgan Chase & Co., February 25, 2010
JPMorgan Chase & Co., February 4, 2010

K

King Pharmaceuticals, Inc., March 17, 2010
The Kroger Co., April 12, 2010
The Kroger Co., March 31, 2010

L

Liz Claiborne, Inc., February 25, 2010
Lowe's Companies, Inc., March 22, 2010
Lowe's Companies, Inc., March 18, 2010

M

Marathon Oil Corporation, December 23, 2010
Marathon Oil Corporation, January 8, 2010
Marriott International, Inc., March 17, 2010
Marriott International, Inc., April 19, 2010
Marriott International, Inc., March 12, 2010
Masco Corporation, January 13, 2010
Mattel, Inc., February 3, 2010
Mattel, Inc., January 14, 2010
Mattel, Inc., January 6, 2010
McDermott International, Inc., January 8, 2010
The McGraw-Hill Companies, Inc., February 24, 2010
The McGraw-Hill Companies, Inc., March 17, 2010
MDU Resources Group, Inc., January 16, 2010
Medco Health Solutions, Inc., March 12, 2010
Medco Health Solutions, Inc., January 4, 2010
Medco Health Solutions, Inc., January 26, 2010
Medtronic, Inc., May 17, 2010
Medtronic, Inc., May 13, 2010
Mentor Graphics Corporation, April 5, 2010
Merck & Co., Inc., May 4, 2010
Merck & Co., Inc., February 22, 2010
Merck & Co., Inc., February 19, 2010
Merck & Co., Inc., March 29, 2010
Merck & Co., Inc., February 19, 2010
Merck & Co., Inc., March 29, 2010
Merck & Co., Inc., February 16, 2010
Merck & Co., Inc., January 29, 2010
Monsanto Company, October 18, 2010
Mylan, Inc., March 12, 2010
Mylan Inc., January 4, 2010

N

Navistar International Corporation, December 8, 2010
Navistar International Corporation, January 4, 2011
NBT Bancorp Inc., March 5, 2010
News Corporation, July 27, 2010
NiSource, Inc., March 22, 2010
NiSource, Inc., January 6, 2010
NiSource Inc., February 22, 2010
Noble Romans, Inc., March 12, 2010
Norfolk Southern Corporation, January 15, 2010
Northrop Grumman Corporation, March 18, 2010
NYSE Euronext, February 16, 2010

O

Oak Valley Bancorp, January 13, 2010
Occidental Petroleum Corporation, February 5, 2010
Occidental Petroleum Corporation, January 20, 2010
Omnicom Group Inc., March 29, 2010
Omnicom Group Inc., March 25, 2010
Omnicom Group Inc., March 24, 2010
Omnicom Group Inc., March 11, 2010

P

Patriot Scientific Corporation, September 29, 2010
Patriot Scientific Corporation, October 18, 2010
PepsiCo, Inc., February 26, 2010
PepsiCo, Inc., February 24, 2010
PetSmart, Inc., April 27, 2010
PetSmart, Inc., April 12, 2010
Pfizer Inc., January 20, 2010
Pfizer Inc., February 22, 2010
Pfizer, Inc., January 12, 2010
Pfizer Inc., January 11, 2010
PG&E Corporation, March 11, 2010
PG&E Corporation, March 10, 2010
PG&E Corporation, February 2, 2010
Pinnacle West Capital Corporation, March 1, 2010
Pioneer Natural Resources Company, February 12, 2010
Portland General Electric Company, January 28, 2010
PPG Industries, Inc., January 15, 2010
The Procter & Gamble Company, August 4, 2010
PSB Group, Inc., February 23, 2010
Pulte Homes, Inc., March 17, 2010
Pulte Homes, Inc., February 24, 2010

Q

Questar Corporation, February 17, 2010

R

Range Resources Corporation, February 18, 2010
Range Resources Corporation, January 28, 2010
Raytheon Company, March 31, 2010
Raytheon Company, March 29, 2010
Reynolds American Inc., January 8, 2010
R.R. Donnelley & Sons Company, March 23, 2010
R.R. Donnelley & Sons Company, April 5, 2010

S

Safeway Inc., March 17, 2010
Safeway Inc., January 4, 2010
Safeway, Inc., January 26, 2010
Sempra Energy, March 5, 2010
Smithfield Foods, Inc., July 1, 2010
Smithfield Foods, Inc., June 24, 2010
Spectra Energy Corp., October 7, 2010
Spectra Energy Corporation, October 25, 2010
Sprint Nextel Corporation, March 16, 2010
Sprint Nextel Corporation, April 20, 2010
Sprint Nextel Corporation, March 12, 2010
Sprint Nextel Corporation, March 4, 2010
Sprint Nextel Corporation, February 24, 2010
Staples, Inc., April 2, 2010
State Bancorp, Inc., February 5, 2010
State Street Corporation, February 3, 2010
Streamline Health Solutions, Inc., March 23, 2010
SunTrust Banks, Inc., January 13, 2010
SunTrust Banks, Inc., January 13, 2010
SunTrust Banks, Inc., January 6, 2010
SunTrust Banks, Inc., February 12, 2010
SUPERVALU INC., April 20, 2010
Symantec Corporation, June 3, 2010
Synovus Financial Corp., December 29, 2010

T

Target Corporation, March 31, 2010
Teletouch Communications, Inc.,, September 24, 2010
Textron Inc., January 21, 2010
Time Warner, Inc., February 22, 2010
Time Warner Inc., January 29, 2010
Time Warner Inc., January 26, 2010
Time Warner Inc., March 23, 2010
Total System Service, December 28, 2010
Tyson Foods, Inc., October 22, 2010

U

UAL Corporation, March 11, 2010
Ultra Petroleum Corp., March 26, 2010
Ultra Petroleum Corp., March 12, 2010
Union Pacific Corporation, March 26, 2010
Union Pacific Corporation, March 5, 2010
Union Pacific Corporation, January 29, 2010

V

Vail Resorts, Inc., September 21, 2010
Verizon Communications, Inc., March 2, 2010
Verizon Communications Inc., March 12, 2010
Verizon Communications Inc., February 22, 2010
Verizon Communications Inc., February 19, 2010
Verizon Communications Inc., February 18, 2010
Verizon Communications Inc., February 12, 2010
Verizon Communications Inc., January 28, 2010
Verizon Communications Inc., January 21, 2010
Verizon Communications Inc., January 6, 2010
Verizon Communications Inc., January 6, 2010
Virtual Radiologic Corporation, March 9, 2010

W

Wal-Mart Stores, Inc., March 31, 2010
Wal-Mart Stores, Inc., March 30, 2010
Wal-Mart Stores, Inc., March 30, 2010
Wal-Mart Stores, Inc., March 29, 2010
Wal-Mart Stores, Inc., March 26, 2010
Wal-Mart Stores, Inc., March 26, 2010
Wal-Mart Stores, Inc., March 26, 2010
Wal-Mart Stores, Inc., February 19, 2010
Wal-Mart Stores, Inc., February 19, 2010
The Walt Disney Company, December 27, 2010
The Walt Disney Company, December 22, 2010
Watson Pharmaceuticals, December 29, 2010
Wells Fargo & Company, March 4, 2010
Wells Fargo & Company, February 19, 2010
Wells Fargo & Company, January 14, 2010
The Western Union Company, March 10, 2010
The Western Union Company, March 19, 2010
Whole Foods Market, Inc., December 21, 2010
Winn-Dixie Stores, Inc., September 16, 2010

XYZ

Xcel Energy Inc., March 19, 2010
Xcel Energy Inc., February 12, 2010
XTO Energy Inc., March 4, 2010
Yahoo! Inc., April 2, 2010
Yahoo! Inc., March 24, 2010
Yum! Brands, Inc., March 5, 2010
Yum! Brands, Inc., January 21, 2010

Chronological Listing

Dec Nov Oct Sep Aug Jul Jun May Apr Mar Feb Jan No Response

December

The Coca-Cola Company, December 29, 2010
Synovus Financial Corp., December 29, 2010
Watson Pharmaceuticals, December 29, 2010
Commonwealth Biotechtechnologies, Inc., December 28, 2010
General Electric Company, December 28, 2010
International Business Machines Corporation, December 28, 2010
Total System Service, December 28, 2010
The Walt Disney Company, December 27, 2010
Edison International, December 23, 2010
Marathon Oil Corporation, December 23, 2010
Abbott Laboratories, December 22, 2010
AFLAC Incorporated, December 22, 2010
AT&T Inc., December 22, 2010
CIGNA Corp., December 22, 2010
The Walt Disney Company, December 22, 2010
General Electric Company, December 21, 2010
International Business Machines Corporation, December 21, 2010
Whole Foods Market, Inc., December 21, 2010
Avery Dennison Group, December 20, 2010
AT&T Inc., December 16, 2010
Fortune Brands, Inc., December 16, 2010
Bank of America Corporation, December 15, 2010
Navistar International Corporation, December 8, 2010
Navistar International Corporation, January 4, 2011
Hewlett-Packard Company, December 7, 2010

November

Dominion Resources, Inc., November 16, 2010
Exxon Mobil Corporation, November 16, 2010
AmerisourceBergen Corporation, November 15, 2010
AmerisourceBergen Corporation, December 8, 2010
Jack in the Box Inc., November 12, 2010
GlobalOptions Group, Inc., November 9, 2010
Becton, Dickinson & Company, November 1, 2010

October

Tyson Foods, Inc., October 22, 2010
Cisco Systems, Inc., October 18, 2010
Monsanto Company, October 18, 2010
General Electric Company, October 7, 2010
Spectra Energy Corp., October 7, 2010
Spectra Energy Corporation, October 25, 2010

September

D.R. Horton, Inc., September 30, 2010
Patriot Scientific Corporation, September 29, 2010
Patriot Scientific Corporation, October 18, 2010
Teletouch Communications, Inc.,, September 24, 2010
Vail Resorts, Inc., September 21, 2010
The Hain Celestial Group, Inc., September 16, 2010
The Hain Celestial Group, Inc., October 6, 2010
Winn-Dixie Stores, Inc., September 16, 2010

August

Coach, Inc., August 19, 2010
Archer-Daniels-Midland Company, August 18, 2010
The Procter & Gamble Company, August 4, 2010

July

Hewlett Packard Company, July 28, 2010
News Corporation, July 27, 2010
General Mills, Inc., July 2, 2010
Smithfield Foods, Inc., July 1, 2010

June

Smithfield Foods, Inc., June 24, 2010
Great Plains Energy Incorporated, June 17, 2010
Del Monte Foods Company, June 3, 2010
Symantec Corporation, June 3, 2010

May

Medtronic, Inc., May 17, 2010
Medtronic, Inc., May 13, 2010
Merck & Co., Inc., May 4, 2010

April

PetSmart, Inc., April 27, 2010
Devon Energy Corporation, April 20, 2010
SUPERVALU INC., April 20, 2010
CB Richard Ellis Group, Inc., April 15, 2010
Chesapeake Energy Corporation, April 13, 2010
Abercrombie & Fitch Co., April 12, 2010
The Kroger Co., April 12, 2010
PetSmart, Inc., April 12, 2010
BioSpecifics Technologies Corp., April 5, 2010
Celgene Corporation, April 5, 2010
Mentor Graphics Corporation, April 5, 2010
Altria Group, Inc., April 2, 2010
Altria Group, Inc., April 20, 2010
Chesapeake Energy Corporation, April 2, 2010
Staples, Inc., April 2, 2010
Yahoo! Inc., April 2, 2010
Chevron Corporation, April 1, 2010
Great Plains Energy Incorporated, April 1, 2010

March

Caterpillar Inc., March 31, 2010
DaVita Inc., March 31, 2010
InterDigital, Inc., March 31, 2010
Raytheon Company, March 31, 2010
Target Corporation, March 31, 2010
The Kroger Co., March 31, 2010
Wal-Mart Stores, Inc., March 31, 2010
Caterpillar Inc., March 30, 2010
Wal-Mart Stores, Inc., March 30, 2010
Wal-Mart Stores, Inc., March 30, 2010
Omnicom Group Inc., March 29, 2010
Raytheon Company, March 29, 2010
Wal-Mart Stores, Inc., March 29, 2010
Ultra Petroleum Corp., March 26, 2010
Union Pacific Corporation, March 26, 2010
Wal-Mart Stores, Inc., March 26, 2010
Wal-Mart Stores, Inc., March 26, 2010
Wal-Mart Stores, Inc., March 26, 2010
The Goldman Sachs Group, Inc., March 25, 2010
Omnicom Group Inc., March 25, 2010
Omnicom Group Inc., March 24, 2010
Yahoo! Inc., March 24, 2010
R.R. Donnelley & Sons Company, March 23, 2010
R.R. Donnelley & Sons Company, April 5, 2010
Streamline Health Solutions, Inc., March 23, 2010
Amazon.com, Inc., March 22, 2010
Amazon.com, Inc., April 7, 2010
CoBiz Financial Inc., March 22, 2010
Continental Airlines, Inc., March 22, 2010
Lowe's Companies, Inc., March 22, 2010
NiSource, Inc., March 22, 2010
Exxon Mobil Corporation, March 19, 2010
Exxon Mobil Corporation, March 19, 2010
JPMorgan Chase & Co., March 19, 2010
Xcel Energy Inc., March 19, 2010
Comcast Corporation, March 18, 2010
Ensco International plc, March 18, 2010
Lowe's Companies, Inc., March 18, 2010
Northrop Grumman Corporation, March 18, 2010
Comcast Corporation, March 17, 2010
King Pharmaceuticals, Inc., March 17, 2010
Marriott International, Inc., March 17, 2010
Marriott International, Inc., April 19, 2010
Pulte Homes, Inc., March 17, 2010
Safeway Inc., March 17, 2010
JPMorgan Chase & Co., March 16, 2010
Sprint Nextel Corporation, March 16, 2010
Sprint Nextel Corporation, April 20, 2010
Ford Motor Company, March 12, 2010
Goldman Sachs Group, Inc., March 12, 2010
The Home Depot, Inc., March 12, 2010
Intel Corporation, March 12, 2010
JPMorgan Chase & Co., March 12, 2010
Marriott International, Inc., March 12, 2010
Medco Health Solutions, Inc., March 12, 2010
Mylan, Inc., March 12, 2010
Noble Romans, Inc., March 12, 2010
Sprint Nextel Corporation, March 12, 2010
Ultra Petroleum Corp., March 12, 2010
International Paper Company, March 11, 2010
The Goldman Sachs Group, Inc., March 11, 2010
InterDigital, Inc., March 11, 2010
Omnicom Group Inc., March 11, 2010
PG&E Corporation, March 11, 2010
UAL Corporation, March 11, 2010
PG&E Corporation, March 10, 2010
The Western Union Company, March 10, 2010
The Western Union Company, March 19, 2010
Central Federal Corporation, March 8, 2010
Comcast Corporation, March 9, 2010
CVS Caremark Corporation, March 9, 2010
The Goldman Sachs Group, Inc., March 9, 2010
Virtual Radiologic Corporation, March 9, 2010
Alaska Air Group, Inc., March 8, 2010
Goldman Sachs Group, Inc., March 8, 2010
Intel Corporation, March 8, 2010
JPMorgan Chase & Co., March 8, 2010
Comcast Corporation, March 5, 2010
JPMorgan Chase & Co., March 5, 2010
JPMorgan Chase & Co., March 26, 2010
JPMorgan Chase & Co., March 5, 2010
JPMorgan Chase & Co., March 5, 2010
NBT Bancorp Inc., March 5, 2010
Sempra Energy, March 5, 2010
Union Pacific Corporation, March 5, 2010
Yum! Brands, Inc., March 5, 2010
Casade Financial Corporation, March 4, 2010
Casade Financial Corporation, March 4, 2010
Freeport-McMoRan Copper & Gold Inc., March 4, 2010
IDACORP Inc., March 4, 2010
Sprint Nextel Corporation, March 4, 2010
Wells Fargo & Company, March 4, 2010
XTO Energy Inc., March 4, 2010
Bank of America Corporation, March 3, 2010
The Allstate Corporation, March 3, 2010
AT&T Inc., March 2, 2010
Bank of America Corporation, March 2, 2010
Verizon Communications, Inc., March 2, 2010
Verizon Communications Inc., March 12, 2010
Allegheny Technologies Incorporated, March 1, 2010
AT&T Inc., March 1, 2010
AT&T Inc., March 12, 2010
Bank of America Corporation, March 1, 2010
Ford Motor Company, March 1, 2010
Genzyme Corporation, March 1, 2010
Pinnacle West Capital Corporation, March 1, 2010

February

Bank of America Corporation, February 26, 2010
EMC Corporation, February 26, 2010
EMC Corporation, March 10, 2010
Exelon Corporation, February 26, 2010
PepsiCo, Inc., February 26, 2010
Cascade Financial Corporation, February 25, 2010
CVS Caremark Corporation, February 25, 2010
The First Bancorp, Inc., February 25, 2010
JPMorgan Chase & Co., February 25, 2010
Liz Claiborne, Inc., February 25, 2010
The Allstate Corporation, February 24, 2010
Bank of America Corporation, February 24, 2010
Bank of America Corporation, February 24, 2010
The McGraw-Hill Companies, Inc., February 24, 2010
The McGraw-Hill Companies, Inc., March 17, 2010
PepsiCo, Inc., February 24, 2010
Pulte Homes, Inc., February 24, 2010
Sprint Nextel Corporation, February 24, 2010
AT&T Inc., February 23, 2010
Citigroup Inc., February 23, 2010
PSB Group, Inc., February 23, 2010
Allergan, Inc., February 22, 2010
Bank of America Corporation, February 22, 2010
Cascade Financial Corporation, February 22, 2010
Cascade Financial Corporation, February 22, 2010
Cascade Financial Corporation, February 22, 2010
Citigroup Inc., February 22, 2010
Comcast Corporation, February 22, 2010
Comcast Corporation, March 23, 2010
Continental Airlines, Inc., February 22, 2010
International Business Machines Corporation, February 22, 2010
International Business Machines Corporation, March 24, 2010
Johnson & Johnson, February 22, 2010
Merck & Co., Inc., February 22, 2010
Time Warner, Inc., February 22, 2010
Verizon Communications Inc., February 22, 2010
American Express Company, February 19, 2010
The Charles Schwab Corporation, February 19, 2010
Gilead Sciences, Inc., February 19, 2010
Henry Schein, Inc., February 19, 2010
Honeywell International Inc., February 18, 2010
Merck & Co., Inc., February 19, 2010
Merck & Co., Inc., March 29, 2010
Merck & Co., Inc., February 19, 2010
Merck & Co., Inc., March 29, 2010
Verizon Communications Inc., February 19, 2010
Wal-Mart Stores, Inc., February 19, 2010
Wal-Mart Stores, Inc., February 19, 2010
Wells Fargo & Company, February 19, 2010
Range Resources Corporation, February 18, 2010
Verizon Communications Inc., February 18, 2010
Questar Corporation, February 17, 2010
The Coca-Cola Company, February 17, 2010
The Coca-Cola Company, March 3, 2010
AT&T Inc., February 16, 2010
AT&T Inc., March 2, 2010
Bank of America Corporation, February 16, 2010
E.I. du Pont de Nemours and Company, February 16, 2010
E. I. DuPont de Nemours and Company, February 16, 2010
E.I. du Pont de Nemours and Company, March 16, 2010
Exxon Mobil Corporation, February 16, 2010
Exxon Mobil Corporation, February 16, 2010
Exxon Mobil Corporation, March 23, 2010
Merck & Co., Inc., February 16, 2010
NYSE Euronext, February 16, 2010
Allegheny Energy, Inc., February 12, 2010
AMR Corporation, February 12, 2010
AMR Corporation, February 12, 2010
AT&T Inc., February 12, 2010
Exxon Mobil Corporation, February 12, 2010
The Goldman Sachs Group, Inc., February 12, 2010
The Goldman Sachs Group, Inc., February 12, 2010
Halliburton Company, February 12, 2010
Halliburton Company, March 19, 2010
Halliburton Company, February 12, 2010
Halliburton Company, March 19, 2010
Pioneer Natural Resources Company, February 12, 2010
Verizon Communications Inc., February 12, 2010
Xcel Energy Inc., February 12, 2010
The Boeing Company, February 6, 2010
Chevron Corporation, February 6, 2010
Chevron Corporation, March 1, 2010
The Allstate Corporation, February 5, 2010
The Boeing Company, February 5, 2010
Occidental Petroleum Corporation, February 5, 2010
State Bancorp, Inc., February 5, 2010
Great Plains Energy Incorporated, February 4, 2010
JPMorgan Chase & Co., February 4, 2010
The Boeing Company, February 3, 2010
EOG Resources, Inc., February 3, 2010
Goldman Sachs Group, February 3, 2010
Goldman Sachs Group, Inc., February 22, 2010
Intel Corporation, February 3, 2010
Mattel, Inc., February 3, 2010
State Street Corporation, February 3, 2010
American Express Company, February 2, 2010
Energen Corporation, February 2, 2010
PG&E Corporation, February 2, 2010
Alpha Natural Resources, Inc., February 1, 2010
Bank of America Corporation, February 1, 2010
The Boeing Company, February 1, 2010
E.I. du Pont de Nemours and Company, February 1, 2010

January

Bank of America, January 29, 2010
Bank of America Corporation, March 8, 2010
The Boeing Company, January 29, 2010
Cleco Corporation, January 29, 2010
Comcast Corporation, January 29, 2010
Merck & Co., Inc., January 29, 2010
Time Warner Inc., January 29, 2010
Union Pacific Corporation, January 29, 2010
Verizon Communications Inc., January 28, 2010
The Boeing Company, January 27, 2010
Bristol-Myers Squibb Company, January 28, 2010
Cabot Oil & Gas Corporation, January 28, 2010
Express Scripts Inc., January 28, 2010
International Paper Company, January 28, 2010
Portland General Electric Company, January 28, 2010
Range Resources Corporation, January 28, 2010
Abbott Laboratories, January 27, 2010
Citigroup Inc., January 27, 2010
The Dow Chemical Company, January 27, 2010
Exxon Mobil Corporation, January 27, 2010
General Dynamics Corporation, January 27, 2010
CIGNA Corporation, January 26, 2010
Frontier Communications Corporation, January 26, 2010
Time Warner Inc., January 26, 2010
Time Warner Inc., March 23, 2010
Aetna Inc., January 25, 2010
Frontier Communications Corporation, January 25, 2010
General Electric Company, January 23, 2010
Ball Corporation, January 25, 2010
Ball Corporation, March 12, 2010
International Business Machines Corporation, January 22, 2010
Citigroup Inc., January 21, 2010
Exxon Mobil Corporation, January 21, 2010
Exxon Mobil Corporation, March 23, 2010
Halliburton Company, January 21, 2010
Textron Inc., January 21, 2010
Verizon Communications Inc., January 21, 2010
Yum! Brands, Inc., January 21, 2010
Central Pacific Financial Corp., January 20, 2010
Occidental Petroleum Corporation, January 20, 2010
Pfizer Inc., January 20, 2010
Pfizer Inc., February 22, 2010
The Charles Schwab Corporation, January 19, 2010
Citigroup Inc., January 19, 2010
Danaher Corporation, January 19, 2010
Dominion Resources, Inc., January 19, 2010
Dominion Resources, Inc., March 29, 2010
Honeywell International Inc., January 19, 2010
MDU Resources Group, Inc., January 16, 2010
Brocade Communications Systems, Inc., January 15, 2010
Norfolk Southern Corporation, January 15, 2010
PPG Industries, Inc., January 15, 2010
Brocade Communications Systems, Inc., January 14, 2010
Coachmen Industries, Inc., January 14, 2010
Mattel, Inc., January 14, 2010
Wells Fargo & Company, January 14, 2010
Bank of America Corporation, January 13, 2010
Bank of America Corporation, February 11, 2010
International Business Machines Corporation, January 13, 2010
Johnson & Johnson, January 13, 2010
Masco Corporation, January 13, 2010
Oak Valley Bancorp, January 13, 2010
SunTrust Banks, Inc., January 13, 2010
SunTrust Banks, Inc., January 13, 2010
Abbott Laboratories, January 12, 2010
Entergy Corporation, January 12, 2010
Entergy Corporation, March 16, 2010
Pfizer, Inc., January 12, 2010
EOG Resources, Inc., January 11, 2010
EQT Corporation, January 11, 2010
Fluor Corporation, January 11, 2010
Pfizer Inc., January 11, 2010
First Mariner Bancorp, January 8, 2010
Marathon Oil Corporation, January 8, 2010
McDermott International, Inc., January 8, 2010
Reynolds American Inc., January 8, 2010
Bristol-Myers Squibb Company, January 7, 2010
Gannett Co., Inc. , January 7, 2010
Google, Inc., January 7, 2010
International Business Machines Corporation, January 7, 2010
International Business Machines Corporation, February 22, 2010
Bank Of America Corporation, January 6, 2010
Eastman Chemical Company, January 6, 2010
Fortune Brands, Inc., January 6, 2010
Mattel, Inc., January 6, 2010
NiSource, Inc., January 6, 2010
NiSource Inc., February 22, 2010
SunTrust Banks, Inc., January 6, 2010
SunTrust Banks, Inc., February 12, 2010
Verizon Communications Inc., January 6, 2010
Verizon Communications Inc., January 6, 2010
CSX Corporation, January 5, 2010
CVS Caremark Corporation, January 5, 2010
CVS CaremarkCorporation, January 26, 2010
AT&T Inc., January 4, 2010
Citigroup Inc., January 4, 2010
Honeywell International Inc., January 4, 2010
Honeywell International Inc., January 26, 2010
International Business Machines Corporation, January 4, 2010
Medco Health Solutions, Inc., January 4, 2010
Medco Health Solutions, Inc., January 26, 2010
Mylan Inc., January 4, 2010
Safeway Inc., January 4, 2010
Safeway, Inc., January 26, 2010

No Response

Apache Corporation (no response)

http://www.sec.gov/divisions/corpfin/cf-noaction/2010_14a-8.shtml

Modified: 01/25/2013