1.

We note from your disclosures in Note 7 that it appears you have included the HomeLink business, a wireless vehicle/home communication business acquired during 2013, in your Automotive Products segment, which primarily designs and manufactures interior and exterior automotive mirrors. Please tell us the consideration given by management in determining your reportable operating segments in light of this significant acquisition

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•	Historically since 2003, as part of a licensing arrangement, the Company has been selling interior auto-dimming rearview mirrors with the HomeLink feature integrated into our mirrors with numerous automotive OEMs worldwide.  As such, prior to the acquisition of HomeLink by the Company, sales of HomeLink were reported within the Automotive Products segment.

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The Company reports financial information with respect to HomeLink internally (to both management and the Board of Directors) as an individual product line of the Company, similar to how it reports financial information of other product lines (e.g., interior auto-dimming mirrors, and exterior auto-dimming mirrors). The financial information reported for each product line consists only of sales, cost of sales, and gross profit. Financial information below the gross profit line is not compiled for such product lines. The Company does not internally or otherwise allocate specific operating expenses to individual product lines in the Automotive Products segment. Similarly, prior to the acquisition, HomeLink was characterized as a product line in the Automotive Experience Segment by Johnson Controls Inc. Operating expenses are instead allocated on a combined basis in the Automotive

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While the financial information by product line referred to above is reviewed by our Chief Operating Decision Maker (“CODM”), it is not used to assess overall performance or make resource allocation decisions.  Forecasted information provided to the CODM does not extend below the sales line item level.  Rather, our CODM regularly reviews the discrete financial information of the Automotive Products operating segment (which reflects the operating results of all product lines) to assess the overall performance and to make resource allocation decisions for the Company.

•	David Christian - Operations Manager, Fire Protection

•	Elizabeth Diekevers - Executive Administrative Assistant

•	Steven Downing - VP of Finance, CFO

◦	Steven Bell - Financial Analyst

◦	Gabriel Brown - Commercial Manager

◦	Clifford Burgess - Director of Information Technology

◦	Robert Hughes - Director of Finance and Tax

◦	Angela Nadeau - Director of Commercial Management

◦	Kevin Nash - VP of Accounting, CAO

◦	Laura Sawinski - Travel Coordinator

◦	Rebecca Sweezea - Travel Coordinator

◦	James Trainor - Commercial Manager

◦	Jason Van Every - Business Forecast Manager

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•	Paul Flynn Jr. - VP of Operations

•	Mathias Fox - Director of Mechanical Engineering

•	Sue Franz - VP of Chemistry

•	Scott Heerema - Director of Facilities

•	Kenneth Horner - VP of Quality Assurance

•	Yong-Ho Lee - General Manager Korea

•	Mark Newton - Senior Vice President

◦	Neil Boehm - Senior Engineering Director

◦	Bradley Bosma - VP of European Business

◦	Martin Budek - Sales Manager

◦	Matthew Chiodo - Sales Director

◦	David Driscoll - Program Manager

◦	David Falb - Engineering Manager Camera Systems

◦	William Juhasz Jr. - Sales Engineer

◦	Che Krause - Sales Director

◦	Thomas Latsko - Sales Director

◦	Ethan Lee -Engineering Manager - Display Audio Systems

◦	Joseph Matthews - VP of Purchasing

◦	Barry Nelson - Engineering Manager Research Test

◦	Douglas Newhouse - Sales Director

◦	Bo Pan - General Manager - China

◦	Craig Piersma - Director of Marketing

◦	Tom Sherman - Engineering Manager Electronics

◦	Marc Smeyers - Engineering Director Electrical Engineering

◦	Geoffrey Wright - Sales Engineer

•	Kazuhiko Nishijima - General Manager Japan

•	Lori Querback - Administrative Assistant

•	Elliott Richards - Engineering Manager Data Management

•	Wayne Rumsey - Engineering Manager CAE

•	Scott Ryan - Patent Attorney

•	David Schmidt - Engineering Manager Software Development

•	Paul St. Amour - Chief Pilot

•	William Tonar - VP of Applied Materials

•	Kurtis Wassink - Director of Human Resources

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•	For the three months ended September 30, 2014:

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As a percentage of net sales, cost of goods sold decreased to 60.5% for the third quarter of 2014 versus 63.3% in the third quarter of 2013, primarily due to the impact of the HomeLink acquisition, improvements in product mix, and purchasing cost reductions, which were partially offset by annual customer price reductions. Each of the positive factors is estimated to have impacted cost of goods sold independently as a percentage of net sales by approximately 125 - 150 basis points.

•	For the Nine months ended September 30, 2014:

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As a percentage of net sales, cost of goods sold for the nine months ended September 30, 2014 declined to 60.6%, down from 64.3% in the same period last year primarily due to the impact of the HomeLink® acquisition, improvements in product mix, and purchasing cost reductions, which were partially offset by annual customer price reductions. Each of the positive factors is estimated to have impacted cost of goods sold independently as a percentage of net sales by approximately 150 - 200 basis points.

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