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kayakzz

05/25/12 11:46 AM

#13182 RE: dhjr123 #13179

Letter from SEC to GLER dated February 28, 2011:

We note you indicate that Sydney Harland received “other annual compensation” of $3,148,583 in 2010 as compared to $247,000 in 2008 and 2009. Please tell us why Mr. Harland’s compensation increased so significantly, in particular given the Company’s net
loss in 2010; also include this disclosure in future filings.

Page 3 of http://sec.gov/Archives/edgar/data/1121901/000000000011012745/filename1.pdf