We maintain disclosure controls and procedures designed to provide
reasonable assurance that information required to be timely disclosed is
accumulated and communicated to management in a timely fashion.
Management has assessed the eff ectiveness of these disclosure controls
and procedures as of January 31, 2012, and determined they were eff ective
as of that date to provide reasonable assurance that information required
to be disclosed by us in the reports we fi le or submit under the Securities
Exchange Act of 1934, as amended, was accumulated and communicated
to management, as appropriate, to allow timely decisions regarding
required disclosure and were eff ective to provide reasonable assurance
that such information is recorded, processed, summarized and reported
within the time periods specifi ed by the SEC’s rules and forms.