CORRESP 1 filename1.htm seccommentresponse11142008.htm
November 14, 2008


Mr. H. Christopher Owings
Assistant Director
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549

 
RE:
Dominion Resources, Inc.
 
Correspondence Submitted on August 22, 2008 Regarding
 
Annual Report on Form 10-K for the Year Ended December 31, 2007
 
Filed February 28, 2008
 
Definitive Proxy Statement on Schedule 14A
 
Filed April 4, 2008
 
File No. 1-08489


Dear Mr. Owings:

Dominion Resources, Inc. (the Company) received the Staff's letter dated October 17, 2008, which provided comments on the above-referenced documents.  References to "Dominion" in the letter refer to Dominion Resources, Inc. and its consolidated subsidiaries. This response letter has been filed on EDGAR, and a copy has been sent by facsimile.

For your convenience, the Staff's comments are set forth below and are followed by the Company's responses.

General

1.
We note your responses to comments 1, 6, 7, and 8 in our letter dated August 8, 2008. In those responses, you state that you will take our comments into account as you work on future filings. Please provide us with your intended disclosure for the future filings.

Response
In our response to each comment below, we have described the elements and scope of any intended disclosure for future filings.  We have done this by presenting revisions to the disclosures contained in our Annual Report on Form 10-K filed February 28, 2008 (2007 10-K) and our Definitive Proxy Statement on Schedule 14A filed April 4, 2008 (2008 Proxy Statement) based on our current facts and circumstances.  These disclosures are for illustrative purposes only and any actual future disclosures will reflect the facts and circumstances that exist at the time of the related filing.  Also, we note that some of the anticipated responses involve activities of our Compensation, Governance and Nominating Committee (CGN Committee) and any future filings will be subject to their review and comments.  Also, our future disclosures will consider any future guidance, interpretations or new rules issued by the SEC or Staff on these matters and, as a result, the illustrative disclosures provided in this letter may change accordingly.

Annual Report on Form 10-K for the Year Ended December 31, 2007

Item 7. Management’s Discussion and Analysis of Financial Condition, page 21

2.
In response to comment 1 in our letter dated August 8, 2008, in future filings, please discuss the reason or reasons that there has been higher energy use in your electric transmission and distribution operations and how you have made your operations and maintenance spending more efficient. Also, please discuss how the recent escalation in certain commodity prices has affected you. Finally, please update the proposed disclosure to take into consideration recent events affecting the credit market and such impact on your ability to execute your business plan, including your ability to fund capital expenditures, and discuss any effect on your ability to pay dividends and fund your stock repurchase program.

 
Response
Electric Transmission and Distribution Operations
We anticipate revising the discussion of our electric transmission and distribution operations in Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations as follows:

“In our electric transmission and distribution operations, we are seeing continued strong growth in new customers and increased usage per customer on a weather-normalized basis. Growth is particularly strong in the major metropolitan areas of Virginia.
We believe that higher energy usage is influenced by several factors including the trend towards larger homes for residential customers and the proliferation of home electronic devices such as computers and televisions. Another factor is the growing number of energy-intensive computer data centers located in our Northern Virginia service territory.
Efficient operations and maintenance spending has also been critical to our performance. We have implemented an asset management process to ensure that we are optimizing our investments to balance cost, performance and risk. One such investment has been the installation of automated meter reading equipment, which allows for more accurate billing while requiring less manpower and resources. We continue to focus on making our operations more efficient through automation and the use of technology.”

Impact of Commodity Prices
In 2007, our exposure to commodity price risk was significantly reduced due to the sale of our non-Appalachian E&P business and the reinstatement of annual fuel rate adjustments, effective July 1, 2007, for the Virginia jurisdiction of our utility generation operations, with deferred fuel accounting for over- or under-recoveries of fuel costs.  While we continue to have exposure to commodity price risk through our other businesses, such as our merchant generation and Appalachian E&P operations, we believe this is adequately disclosed in our 2007 10-K as shown in the following excerpts from that filing:

In Item 1A. Risk Factors on page 15, we disclose:
 
·
“We use derivative instruments, including futures, swaps, forwards, options and financial transmission rights to manage our commodity and financial market risks. In addition, we purchase and sell commodity-based contracts primarily in the natural gas market for trading purposes. We could recognize financial losses on these contracts as a result of volatility in the market values of the underlying commodities or if the counterparty fails to perform under a contract.”
 
·
“The success of our merchant power business depends upon favorable market conditions as well as our ability to find buyers willing to enter into power purchase agreements at prices sufficient to cover operating costs. We attempt to manage these risks by entering into both short-term and long-term fixed price sales and purchase contracts and locating our assets in active wholesale energy markets. However, high fuel and commodity costs and excess capacity in the industry could adversely impact our results of operations.”
 
·
“In addition, we use derivatives to hedge future sales of our merchant generation and gas production, which may limit the benefit we would otherwise receive from increases in
 
commodity prices. These hedge arrangements generally include collateral requirements that require us to deposit funds or post letters of credit with counterparties to cover the fair value of covered contracts in excess of agreed upon credit limits. When commodity prices rise to levels substantially higher than the levels where we have hedged future sales, we may be required to use a material portion of our available liquidity and obtain additional liquidity to cover these collateral requirements. In some circumstances, this could have a compounding effect on our financial liquidity and results of operations.”
 
·
“Factors that may affect our financial results include, but are not limited to: damage to or suspension of operations caused by weather, fire, explosion or other events at our or third-party gas and oil facilities, fluctuations in natural gas and crude oil prices, results of future drilling and well completion activities, our ability to acquire additional land positions in competitive lease areas, drilling cost pressures, operational risks that could disrupt production, drilling rig availability and geological and other uncertainties inherent in the estimate of gas and oil reserves.”
 
·
“Short-term market declines in the prices of natural gas and oil could adversely affect our financial results by causing a permanent write-down of our natural gas and oil properties as required by the full cost method of accounting. Under the full cost method, all direct costs of property acquisition, exploration and development activities are capitalized. If net capitalized costs exceed the present value of estimated future net revenues based on hedge-adjusted period-end prices from the production of proved gas and oil reserves (the ceiling test) at the end of any quarterly period, then a permanent write-down of the assets must be recognized in that period.”

In Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations on pages 24 and 25, we disclose:
 
·
“The gas transmission pipeline and storage business serves Dominion’s gas distribution businesses and other customers in the Northeast, mid-Atlantic and Midwest. Included in our gas transmission pipeline and storage businesses is our gas gathering and extraction activity, which sells extracted products at market rates. Revenue provided by our regulated gas transmission and storage, and LNG operations is based primarily on rates established by FERC. The profitability of these businesses is dependent on our ability, through the rates we are permitted to charge, to recover costs and earn a reasonable return on our capital investments. Variability in earnings results from changes in rates and the demand for services, which can be dependent upon weather, changes in commodity prices, and changes in the cost of routine maintenance and repairs (including labor and benefits).”
 
·
“Our Appalachian natural gas E&P business generates income from the sale of natural gas and oil we produce from our reserves, including fixed-term overriding royalty interests formerly associated with volumetric production payment (VPP) agreements as discussed in Note 13 to our Consolidated Financial Statements. Variability in earnings relates to: changes in commodity prices, which are largely market-based; production volumes, which are impacted by numerous factors including drilling success and timing of development projects; and drilling costs which may be impacted by drilling rig availability and other external factors. We manage commodity price volatility by hedging a substantial portion of our expected production. These hedging activities may require cash deposits to satisfy collateral requirements.”
 
·
“Earnings from Dominion Energy’s other nonregulated business, producer services, are subject to variability associated with changes in commodity prices. Producer services uses physical and financial arrangements to hedge this price risk.”
 
·
“Variability in earnings provided by the merchant fleet relates to changes in market-based prices received for electricity and the demand for electricity, which is primarily dependent upon weather. We manage price volatility by hedging a substantial portion of our expected sales. Variability also results from changes in the cost of fuel consumed, labor and benefits and the timing, duration and costs of scheduled and unscheduled outages.”
Also in Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations, on pages 30 through 33, in our Analysis of Consolidated Operations section, we disclose the impact of realized prices on various income statement line items including those related to our merchant generation and Appalachian E&P operations. Additionally, on page 35, for our Appalachian E&P operations, we disclose:
 
·
average realized prices with and without hedging for the periods covered by the income statement; and
 
·
volumes and weighted average prices associated with hedges in place at period end.

We also provide disclosures regarding our exposure to commodity price risk in Item 7A. Quantitative and Qualitative Disclosures About Market Risk on page 49.

In conclusion, we believe that the foregoing disclosures from our 2007 10-K adequately address the impact of changes in commodity prices on Dominion.

Impact of Recent Credit Market Events
In this case, rather than providing sample revisions to our 2007 10-K disclosures, we have provided disclosure from our third quarter 2008 Form 10-Q regarding the impact of recent credit market events on our ability to execute our business plan, including our ability to fund capital expenditures and pay dividends.  In that filing, we included the following disclosure in Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations on page 43:

“Despite recent disruptions in the credit markets, we have sufficient access to liquidity for our daily operations through our credit facilities discussed in Note 15 to our Consolidated Financial Statements. While we continue to issue commercial paper, in October 2008 we borrowed $870 million from our credit facilities to reduce our exposure to the commercial paper market. We expect our operations to provide sufficient cash flow to fund maintenance capital expenditures and maintain or grow our dividend; however we expect to access the capital markets to fund growth capital expenditures. If necessary, we have the flexibility to mitigate the need for future debt financings and equity issuances, by postponing or cancelling certain planned capital expenditures without significantly impacting our earnings per share growth plans over the next several years. However, a material reduction or delay in growth projects would likely reduce our earnings per share growth rate longer term.”

We did not make any new disclosures with respect to our stock repurchase program in our third quarter 2008 Form 10-Q. We currently have no plans to engage in stock repurchases given our expectation that we will make long-term debt and equity issuances to fund our growth capital expenditure program. Additionally, in Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations on pages 39 and 40 of our 2007 10-K, we disclosed that we expected to receive proceeds from stock issuances through our direct stock purchase plan and employee savings plans of between $200 million to $250 million in 2008.  While we also disclosed the remaining stock repurchase authorization provided by our Board of Directors, we did not disclose any plans for future stock repurchases.

 
Definitive Proxy Statement on Schedule 14A

 
Item 1 – Election of Directors, page 10

3.
In response to comment 6 in our letter dated August 8, 2008, in future filings, please provide a description of each director nominee that reflects the business experience of that director for the past five years without any gaps or ambiguities. For example, in your description of Peter W. Brown’s business experience, you state only that he is currently a physician in Virginia Surgical Associates and a director of Bassett Furniture Industries, Inc. As another example, you state only that Robert S. Jepson, Jr.’s business experience is that he is currently chairman and chief executive officer of Jepson Associates, Inc.

 
Response
In future filings, we will provide a description of each director nominee that includes specific dates and reflects the business experience of that director for the past five years without any gaps or ambiguities.  Using Mr. Jepson as an example, his description in the 2008 Proxy Statement would be as follows:

“Robert S. Jepson, Jr., 65, has been a director of Dominion since 2003.  Mr. Jepson has been chairman and chief executive officer of Jepson Associates, Inc., a private investment firm, since 1989.  He received his undergraduate and graduate degrees in business and commerce from the University of Richmond.  Mr. Jepson is the principal contributor and founder of the University of Richmond’s Jepson School of Leadership Studies.  Mr. Jepson serves on the Audit and Compensation, Governance and Nominating Committees.”

 
Compensation Discussion and Analysis, page 14

4.
In your response to comment 7 in our letter dated August 8, 2008, you state that if you engage in any benchmarking, in future filings, you will provide greater detail regarding these benchmarks and will identify the benchmark components. However, it appears that you already benchmark the components of base pay, annual incentive pay, long-term pay, and total compensation of each officer’s position against one or more appropriate job matches from certain surveys, based on primary job responsibilities and scope of the position, which is typically based on revenue or asset size, and in some circumstance, on number of employees. Therefore, if true, in future filings, please provide greater detail regarding these benchmarks and identify their components.

Response
As to our prior practices, we have used broad-based third-party survey data and data from surveys that are industry specific to compare our compensation levels to those in the market for companies with similar revenue size.  Typically, more than 1,000 companies participate in a broad-based survey and from 90 to 300 companies participate in an industry specific survey. Due to the broad participation in the third-party surveys, we review the survey data without considering or identifying the companies that participate in each survey and we do not analyze compensation practices of individual companies participating in the surveys.  For example, a position match from a particular survey may have had 350 companies out of the 1,000 companies participating in the survey provide data for that particular position match.  We do not analyze the companies participating in the survey to establish which companies have comparable revenue size, or which have similar positions to Dominion and, therefore, we have no way of identifying which 350 companies provided information for that particular position.  In future filings, we will provide a more detailed explanation of how we use comparative compensation information we obtain from survey data and will identify the survey components.

Using the language from the 2008 Proxy Statement, the revised disclosure would read substantially as follows:

“Survey compensation data is used as a reference point for market-pricing the compensation of named executive officers.  As discussed above in Factors in Setting Compensation, this is one of several considerations used in setting compensation at Dominion. We compare the base salary, total cash (base salary plus targeted annual incentive pay), targeted long-term incentive pay, and total direct compensation (total cash plus targeted long-term incentive pay) components of our compensation program against 50th and 75th percentile data.  Generally, our program is designed to pay base and total cash at or slightly above the 50th percentile.  Total direct compensation is targeted between the 50th and 75th percentiles, with actual performance of the incentive-based compensation metrics determining what will actually be earned.

For our named executive officers, we use a combination of survey and peer group information to establish the 50th percentile and the 75th percentile for base salary, total cash, long-term incentive awards, and total direct compensation.  For 2007 compensation decisions, the survey information used for named executive officer positions consisted of the average of three to four broad-based or industry-specific surveys of compensation paid to officers holding similar positions at companies
with corporate revenues consistent with our revenues.  The survey average and the peer group average compensation were equally weighted to determine the percentile information.  The component companies of the surveys used in 2007 are listed in Appendix A.  The peer group companies are identified below under The Peer Group.

Due to the broad participation in the surveys, we do not compare our financial performance against any of the survey population.  We consider our peer companies to be more relevant and we do review our financial performance against our peer companies as part of our annual compensation setting process, as described above under Our Process and below under The Peer Group and Peer Group Comparisons.”

The Annual Incentive Program, page 17

5.
In response to comment 8 in our letter dated August 8, 2008, you state that the safety, emergency response, response to power outages, environmental, and other targets were discretionary goals by which you could reduce payouts, rather than necessary targets to be achieved to earn a full payout. Therefore, you did not deem these goals to be material and did not provide a quantitative discussion of the terms of each operating and stewardship target. In future filings, please provide these goals and a quantitative discussion of the terms of each operating and stewardship target.

 
Response
In future filings, we will provide a detailed description and quantitative discussion of the terms of each operating and stewardship goal that applies to the named executive officers under the terms of an incentive plan, unless we have determined in good faith that such target is not a material component of the company’s executive compensation policies or decisions or that disclosure of such performance target would result in competitive harm.  If we omit a material performance target, we will discuss how difficult it will be for the executive to achieve the undisclosed target level, factor, or criteria.

As an example, based on the Commission’s comments, we would revise the disclosure regarding operating and stewardship goals on page 19 of the 2008 Proxy Statement to read as follows:

“Each business unit establishes and scores its own operating and stewardship goals and Mr. Farrell reviews the scores for each officer.  As discussed above under How We Determine AIP Payout Scores, the operating and stewardship goal category is not a component of the weighted goal categories for Mr. Farrell and Mr. Chewning.  For the other named executive officers, operating and stewardship are discretionary goals, rather than necessary targets to be achieved to earn a full payout.  If the goals are not fully achieved, the CGN Committee may apply negative discretion to reduce a payout.

Mr. McGettrick had operating and stewardship goals in four categories: safety; Fossil and Hydro operating and maintenance (O&M) expenditures and Nuclear production costs; Fossil & Hydro operational performance; and a target Nuclear Equivalent Forced Outage Rate (EFOR).  Each goal carried a 3.75% weighting in the overall 15% weighted operating and stewardship goal category.

Mr. McGettrick’s safety goal was to minimize the OSHA recordable incident rate for Fossil & Hydro and Nuclear operations to a specified target number and due to an accident at the Company’s Salem Harbor Power Station that resulted in three fatalities, Mr. McGettrick’s safety goal score was zero.  Mr. McGettrick’s O&M Expenditure/Production Cost goals were to cap Fossil & Hydro expenses and nuclear production costs at targeted dollar amounts and these goals were exceeded.  His Fossil & Hydro peak operational performance goal was to target availability during peak season months to a specified percentage and this target was also exceeded.  The EFOR target goal was not fully achieved. Under the AIP design, extra credit earned by exceeding operating and stewardship goals in other categories as well as the Six Sigma goal extra credit of 4% could be applied to offset a goal shortfall in any category other than safety or regulatory compliance.  Extra credit was applied to offset the EFOR goal shortfall but could not offset the missed safety goal, resulting in 11.3% overall goal achievement for Mr. McGettrick in the operating and stewardship category.

Mr. Johnson had operating and stewardship goals in five categories: safety, power outage durations, emergency response, customer response to outages, and customer retail acquisition costs.  Each goal carried a 3% weighting in the overall 15% weighted operating and stewardship goal category.

Mr. Johnson’s safety goal was to minimize days away, restricted duty and transferred (DART) incidents to a specified target number and this goal was exceeded.  His power outage duration goal was tied to the System Average Outage Duration Index (SAIDI) and this goal was not achieved due to hurricanes and other major storms.  Mr. Johnson’s emergency response goal was to achieve a target average response time to gas emergencies and this goal was achieved. Mr. Johnson also received full credit for achieving a specified average speed of answer to customer call center calls and meeting a targeted dollar amount for retail acquisition costs.  The Six Sigma goal extra credit of 4% was applied to offset the SAIDI goal shortfall, resulting in 100% goal achievement for Mr. Johnson in the 15% weighted operating and stewardship goal category.

Due to the divestiture of Dominion E&P, Mr. Radtke received a deemed 100% goal achievement credit for his operating and stewardship goals.

The table below summarizes goal achievement for the named executive officers including the discretionary operating and stewardship goals.

 
Consolidated Financial
Goal
Business Unit Financial
Goal
Operating and Stewardship Goals
Six
Sigma
Goals
Final
Goal Achievement
Mr. Farrell
90%
 N/A
N/A
10%
100%
Mr. Chewning
90%
N/A
N/A
10%
100%
Mr. Radtke
25%
50%
15%
10%
100%
Mr. McGettrick
25%
50%
11.3%
10%
96.3%
Mr. Johnson
25%
50%
15%
10%
100%

Based on the missed safety goal in the Generation business unit, the CGN exercised negative discretion and lowered Mr. McGettrick’s payout score to 96.3%.  The other named executive officers were paid out based on a 100% payout score.”

If you have any questions or require further information, please call Ash Sawhney at (804) 771-3962 or fax him at (804) 771-6519 or call me at (804) 819-2450 or fax me at (804) 819-2638.

Sincerely,

/s/ Thomas P. Wohlfarth
Thomas P. Wohlfarth
Senior Vice President and Chief Accounting Officer (Principal Accounting Officer)
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

1-800 CONTACTS, Inc.
21st Century Oncology, Inc.
7-Eleven, Inc.
99 Cents Only Stores
A.T. Kearney, Inc.
AAA National Office
ABM Industries, Inc.
Abt Associates Inc.
Accident Fund Insurance Company of America
ACCO Brands Corporation
ACE Limited - ACE USA
ACUITY
Ada County
ADC Telecommunications
Aditya Birla Minacs
Administaff
Advance Auto Parts
Advocate Healthcare
AEGON USA
Aeronix, Inc.
AET Inc. Ltd.
Aetna, Inc.
AFLAC, Inc.
AGL Resources
Agnesian HealthCare
AIG
AIPSO
Air Frame Manufacturing & Supply Company, Inc.
Air Products and Chemicals
Airlines Reporting Corporation
Airlite Plastics Co.
Akerman Senterfitt
Akzo Nobel, Inc.
Alcoa, Inc.
Allegheny Energy
Allete
Alliance Laundry Systems
Alliant Energy
Alliant Techsystems
Allina Health System
Allstate Corporation
Alltel Corporation
ALSAC/St. Jude Children's Research Hospital
Amcor PET Packaging, Inc.
Ameren Corporation
American Airlines, Inc.
American Cancer Society
American Century Investments
American College of Emergency Physicians
American Electric Power
American Enterprise Group, Inc.
American Express
American Family Insurance
American Greetings
American Institute of Physics
American National Standards Institute
American Red Cross, Louisville Area Chapter
American Signature Inc.
American Transmission
American University
AmeriCredit Corp.
AMERIGROUP Corporation
AmeriHealth Mercy Health Plan
AmeriPride Services Inc.
Ameriprise Financial
AmerisourceBergen Corporation
Ameristar Casinos, Inc.
Amica Mutual Insurance Company
AMN Healthcare, Inc.
Amplifon USA
AmTrust Bank
ANH Refractories Company
Anheuser-Busch Companies, Inc.
Anne Arundel Medical Center
AOL LLC
Apartment Investment and Management Company
APC/MGE Critical Power & Cooling Services
APCapital, Inc.
Apex Systems, Inc.
APL Ltd.
APM Terminals North America Inc.
Apogee Enterprises, Inc.
APP Pharmaceuticals, Inc.
Aptium Oncology
Arby's Restaurant Group
Arch Coal, Inc.
Archer Daniels Midland Company
Archon Group, L.P.
Archstone
Areva NP
Argonaut Group
Argonne National Laboratory
Arkansas Blue Cross Blue Shield
Arlington County Government
Arnold and Porter, LLP
Array Marketing Group, Inc.
ARTEL, Inc.
Arup North America Limited
Ashmore Energy International
Associated Banc-Corp
Assurant, Inc. - Solutions
Asurion
AT&T, Inc.
AtlantiCare Regional Medical Center
 
 
 

 
 
Appendix A
Addendum to response #4 – For illustrative purposes only

Aurora Health Care
Aurora Loan Services
Auto Club Group
Automatic Data Processing (ADP)
Automobile Club of Southern California
AutoZone, Inc.
AvalonBay Communities, Inc.
Aviall, Inc.
Avis Budget Group
Avista
Aviva USA
AXA Equitable
Babson College
Ball State University
Bank of the West
Banner Health
Banner Health - Banner Good Samaritan Medical Center
Baptist Health System, Inc.
Barquin International
Barr Pharmaceuticals, Inc.
Battelle
Bausch & Lomb, Inc.
Baxter International
Baylor Health Care System - Baylor University Medical Center
Baystate Health System
BDO Seidman, LLP
Bechtel Corporation
Bechtel Plant Machinery, Inc.
Belk, Inc.
Best Buy Company, Inc.
BG US Services
Big Lots, Inc.
Bill & Melinda Gates Foundation
Bio-Rad Laboratories
Birmingham-Southern College
Black & Veatch Corporation
Black Hills
Blockbuster Inc.
BloodSource
Blue Cross & Blue Shield of Rhode Island
Blue Cross & Blue Shield of Rhode Island - The Health & Wellness Institute, LLC
Blue Cross and Blue Shield of Alabama
Blue Cross and Blue Shield of Kansas
Blue Cross and Blue Shield of Massachusetts
Blue Cross of Idaho Health Service, Inc.
Blue Cross of Northeastern Pennsylvania
Blue Shield of California
Bluebonnet Credit Union
BlueCross BlueShield of Florida
BlueCross BlueShield of Kansas City
BlueCross BlueShield of Louisiana
BlueCross BlueShield of Nebraska
BlueCross BlueShield of North Carolina
BlueCross BlueShield of South Carolina
Bluegreen Corporation
Bluegreen Corporation - Alliance Marketing
BMW Manufacturing Co., LLC
Board of Governors of the Federal Reserve System
Boart Longyear
Bob Evans Farms, Inc.
Boeing Employees Credit Union
Boise Cascade, LLC
Boise Inc.
BOK Financial, Inc.
Booz Allen Hamilton
Boston Market Corporation
Boston Medical Center HealthNet Plan
Boston Scientific Corporation
Boston University
Bovis Lend Lease
Boy Scouts of America
Brady Corporation
Branch Banking & Trust Company
Bremer Financial Corporation
Brightstar Corporation
British Gas North America, LLC
Broadlane, Inc.
Broadridge Financial Solutions, Inc.
Brookdale Senior Living
Brookhaven National Laboratory
Broward Health
Brown and Caldwell
Bryan Cave LLP
BSH Home Appliances Corporation
Buckingham Asset Management, LLC
Buffets, Inc.
Building Materials Holding Corporation
Burger King Corporation
Busch LLC
Business & Legal Reports, Inc.
Butler Animal Health Supply, LLC
C&S Wholesale Grocers
 
 
 

 
 
Appendix A
Addendum to response #4 – For illustrative purposes only

Cablevision Systems Corporation
CACI International, Inc.
CAE Simuflite Civil Training and Services
CAE Simuflite Military Simulation & Training
California Hospital Association
California Independent System
California Institute of Technology
California ISO
California Pizza Kitchen
Callaway Golf Company
Calpine
Calpine Containers, Inc.
Canadian Pacific US
Capgemini
Capital BlueCross
Capital Metropolitan Transportation Authority
Capital One Financial Corporation
Capital Region Health Care Corporation
CapitalSource
Cardinal Health, Inc.
CareFirst BlueCross BlueShield
Cargill, Inc.
Carilion Clinic
Carlson
Carolinas HealthCare System
Carpenter Technology Corporation
Case New Holland
Catholic Health Initiatives
Catholic Healthcare West (CHW)
Catholic Knights
CBRL Group
CDI Corporation, Inc.
CDI Corporation, Inc. - Business Solutions Group
CDI Corporation, Inc. - MRI
CDI Corporation, Inc. - Todays Staffing
CDM, Inc.
Celestica
Celgard, LLC
Celina Insurance Group
Cemex, Inc. US
Centegra Health System
CenterPoint Energy
Central Georgia Health System/The Medical Center of Central Georgia
Central Vermont Public Service
CenturyTel, Inc.
Ceradyne, Inc.
CGGVeritas
CGI Technologies and Solutions, Inc.
CH2M Hill
Chart Industries, Inc.
Cheniere Energy
Chevron Phillips Chemical Company
Chevy Chase Bank
Chicago Mercantile Exchange, Inc.
Chicago Transit Authority
Children's Healthcare of Atlanta
Children's Hospital and Health System
Children's Hospital Boston
Children's Hospital Central California
Children's Hospitals and Clinics of Minnesota
Children's Medical Center of Dallas
Children's Memorial Hospital
Children's National Medical Center
Chiquita Brands International, Inc.
Choice Hotels International, Inc.
Christian City Convalescent Center
CHRISTUS Health
Chromalox, Inc.
CHS Inc.
Church & Dwight
CIGNA Corporation
Cincinnati Children's Hospital Medical Center
Circuit City Stores, Inc.
Citect, Inc.
Citi North America Operations & Technology
Citizens Financial Group, Inc.
Citizens Property Insurance
City National Bank
 
 
 

 
 
Appendix A
Addendum to response #4 – For illustrative purposes only

City of Austin
City of Charlotte
City of Frederick
City of Greensboro
City of Hope
City of Houston
City of Overland Park, Kansas
City of Redmond
City of Richmond
City Public Service
Clarkston Consulting
Classified Ventures, LLC
Cleco Corporation
Cleveland Brothers Equipment Co., Inc.
Cleveland Catholic Charities
Clifton Gunderson LLP
CMGI
CMS Energy
CMWA
CNA Financial Corporation
Coca-Cola Bottling Company Consolidated
Cogentrix Energy, Inc.
Coinstar, Inc.
Colgate Palmolive Company
College of DuPage
College of William & Mary
Colonial Banc Group
Colorado Springs Utilities
Commonwealth Health Corporation
Community Health Network
Compass Bank
Compass Group North America Division
CompuCom Systems, Inc.
Computer Sciences Corporation
Computer Technology Associates, Inc.
Computershare
ConAgra Foods, Inc.
Concentra, Inc.
Conseco, Inc.
Consolidated Edison
Constellation Energy
Continuum Health Partners
Control Components, Inc.
Convergys Corporation
Cornell University
Corning, Inc.
Corporate Executive Board
Corporate Express USA
Corrections Corporation of America
Country Financial
Covance, Inc.
Covenant Health
Cox Enterprises, Inc.
Cox Target Media
Cranston Print Works Company
Creative Memories
Credit Acceptance Corporation
Crowe Chizek and Company, LLC
Crowley Maritime Corporation
Crown Castle International Corporation
CSX
Cubic Corporation
Culligan International Company
Cummins Inc.
CUNA Mutual Group
Curtiss-Wright Corporation
CVS/Caremark
Daiichi Sankyo, Inc.
Dallas Central Appraisal District
Dal-Tile Corporation
Darden Restaurants, Inc.
Dassault Falcon Jet Corporation
Day & Zimmermann Group, Inc.
DCP Midstream
Deere & Company
Del Monte Foods Company
DeLorme Publishing
Delta Air Lines, Inc.
Denny's Inc.
Denver Health & Hospital Authority
DePaul University
Devon Energy
DeVry, Inc.
Diebold Incorporated
DigitalGlobe
Digitas
Diversified Investment Advisors
DLA Piper US, LLP
Dobbs Temporary Services, Inc. d/b/a Pro Staff Personnel Services ("Pro Staff")
Doherty Employment Group
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Dollar General Corporation
Dollar Thrifty Automotive Group
Dominion Resources, Inc.
Domino's Pizza
Donaldson Company, Inc.
Dorsey & Whitney LLP
Downey Savings & Loan Association
DPL Inc.
Dresser-Rand Company
DSC Logistics
DSW, Inc.
Duke Energy
Duke Realty Corporation
Duke University and School of Medicine
Dunkin' Brands, Inc.
Duquesne Light Holdings, Inc.
Dynegy
E.ON U.S.
EarthLink
Econergy International Corporation
Eddie Bauer Holdings, Inc.
EDFUND
Edison International
EDS
Education Management Corporation
Edward Jones
Edwards Lifesciences, LLC
El Paso Corporation
Electric Power Research Institute
Electro Rent Corporation
Elsevier
EMCOR Group, Inc.
Employers Mutual Casualty Company
Enbridge Energy
Energen
Energizer
Energy Future Holdings
Energy Northwest
ENSCO International, Inc.
Entergy
Enterprise Products Partners, LP
Enzon Pharmaceuticals, Inc.
EOG Resources, Inc.
EPCO
Equifax, Inc.
Equity Office
Erickson Retirement Communities
Erie Insurance Group
Ernst & Young, LLP
Essilor of America
Essroc Cement Corporation
Estee Lauder Companies, Inc.
Esurance, Inc.
Evanston Northwestern Healthcare
Excellus BlueCross BlueShield
Exel, a DPWN Company
Exelon
Exempla Healthcare, Inc.
Express Scripts, Inc.
Faegre & Benson, LLP
Fairmont Raffles Hotels International
Fairview Health Services
Farm Credit Bank of Texas
Farmers Insurance Group
Farmland Foods, Inc.
FBL Financial Group, Inc.
FBR Group
FCCI Insurance Group
Federal Home Loan Bank of Atlanta
Federal Home Loan Bank of Cincinnati
Federal Home Loan Bank of Dallas
Federal Home Loan Bank of Pittsburgh
Federal Reserve Bank of Atlanta
Federal Reserve Bank of Boston
Federal Reserve Bank of Dallas
Federal Reserve Bank of Kansas City
Federal Reserve Bank of Philadelphia
Federal Reserve Bank of Richmond
Federal Reserve Bank of San Francisco
Federal Reserve Bank of St. Louis
Federal Reserve Information Technology
Federal-Mogul Corporation
Federated Investors
FedEx Express
FedEx Freight System
FedEx Kinko's
Fellowes, Inc.
Fender Musical Instruments
Fenwick & West, LLP
Ferguson Enterprises, Inc.
Fermi National Accelerator Laboratory
Ferrellgas
Fidelity Investments
FINRA
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Fireman's Fund Insurance Company
First Data Corporation
First Midwest Bank, Inc.
FirstEnergy
Fleetwood Enterprises, Inc.
Fletcher Allen Health Care
Flint Group
FMOL Health System
Foamex International, Inc.
Foot Locker, Inc.
Forest City Enterprises
Forest Laboratories Inc.
Fox Chase Cancer Center
Fox Networks Group
FPL Group
Freddie Mac
Freedom Communications, Inc.
Fresenius Medical Care NA
Friendly Ice Cream Corporation
G&K Services, Inc.
Gambro, Inc.
Gambro, Inc. - BCT
GameTech International
Gartner, Inc.
GATX Corporation
GCI Communication Corp
GE Healthcare
GEICO
Geisinger Health System
GenCorp, Inc.
General Dynamics Information Technology
General Growth Properties, Inc.
General Nutrition, Inc.
General Parts International, Inc.
Generali USA Life Reassurance Company
Geokinetics
Georgia System Operations Corporation
Georgia Transmission Corporation
GeoVera Holdings, Inc.
Gibraltar
Girl Scouts of the USA
Givaudan US
GKN America Corporation
Glatfelter
Global Payments, Inc.
Gold Fields Exploration, Inc.
Golden Horizons LLC
Golden Innovations
Golden Innovations - AEGIS
Golden Star Resources Ltd.
Golden Ventures LLC
Goodrich Corporation
Goody's Family Clothing
Gordon Food Service
Government Employees Hospital Association, Inc.
Graco, Inc.
Grady Health System
Graham Packaging Company
Grange Mutual Casualty Company
Great American Financial Resources, Inc.
Greater Harris County 9-1-1 Emergency Network
Great-West Life & Annuity
Greenberg Traurig, PA
Group
Group Health Cooperative
GTECH Corporation
Guaranty Financial Group, Inc.
H. E. Butt Grocery Company
H. J. Heinz Company
Haemacure Corporation U.S.
Handango, Inc.
Hannaford Bros. Co.
Harley-Davidson Motor Company
Harman International Industries, Inc.
Harris Associates L.P.
Harris County Hospital District
Harris Interactive Inc.
Harris Teeter, Inc.
Hartford HealthCare Corporation
Harvard Pilgrim Health Care
Harvard University
Harvard Vanguard Medical Associates
Hastings Mutual Insurance Company
Hawaiian Electric
HCA
HD Supply
Health Care Service Corporation
Health Net, Inc.
Health Partners
HealthEast Care System
HealthPartners
HealthSpring, Inc.
Healthways, Inc.
Heartland Regional Medical Center
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Heller Ehrman, LLP
Helmerich & Payne, Inc.
Henkel of America
Henry Ford Health System
Henry Schein, Inc.
Herbalife International of America
Hercules Offshore, Inc.
Herman Miller, Inc.
Hess Corporation
Hexion Specialty Chemicals
Highmark
Hill-Rom Company
Hilti, Inc.
Hines Interests, LLP
HNTB Companies
Holy Spirit Hospital
Honeywell International, Inc.
Horizon Blue Cross Blue Shield of New Jersey
Hospira, Inc.
Hospital of the University of Pennsylvania
Hospital Sisters Health System
Houghton Mifflin Company
Howard Hughes Medical Institute
HSBC-North America
Humana, Inc.
Hunter Douglas Inc.
Hunton & Williams, LLP
Huttig Building Products, Inc.
Hyatt Corporation
Hyundai Motor America
I.C. System, Inc.
IAC/InteractiveCorp
ICMA Retirement Corporation
IDACORP
Idaho Power Company
Idearc Media
IDEXX Laboratories
IKEA USA
IKON Office Solutions
Illinois Municipal Retirement Fund
IMC, Inc.
Immix Management Services
IMS Health
Incepture, Inc.
Independence Blue Cross
Indiana University
Indianapolis Public Schools
Information Handling Services (IHS)
ING North America Insurance Corporation US Financial Services
Ingram Industries, Inc.
Innovative Productivity, Inc.
Inova Health System
Integrys Energy Group
InterContinental Hotels Group Americas
Interface Solutions
Intermountain Health Care, Inc.
International Dairy Queen, Inc.
International Game Technology
International Imaging Materials, Inc.
International Paper Company
International Truck and Engine
Interstate Bakeries Corporation
Invensys Controls
Invesco PLC
Investment Company Institute
ION Geophysical Corporation
iPCS, Inc.
Iron Mountain
ITC Holdings Corp
Itochu International, Inc. North America
ITT Systems Division
J. C. Penney Company, Inc.
J.R. Simplot Company
Jackson Health System
Jackson National Life Insurance Company
Jacobs Engineering Group, Inc.
James City County Government
James Hardie Building Products
JEA
Jefferson County Public Schools
Jefferson Wells International
JetBlue Airways
JM Family
Jo-Ann Fabric & Craft Stores Inc.
Jockey International, Inc.
John Hancock Financial Services, Inc.
John Wiley & Sons, Inc.
Johns Hopkins HealthCare, LLC
Johns Manville
Johnson Controls Power Solutions
Johnson Financial Group
Johnson Outdoors, Inc.
JohnsonDiversey, Inc.
Jones Lang LaSalle
Jordan's Furniture
JPI
Judicial Council of California
K. Hovnanian Companies
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Kaiser Permanente
Kamehameha Schools
Kao Brands Company
Katun Corporation
Kellogg Company
Kelsey-Seybold Clinic
Kemper Auto and Home Group
Kennebunk Savings Bank
Kennedy Health System
Kentucky Higher Education Student Loan Corporation
Kentucky Lottery Corporation
Kerry, Inc. US
Kewaunee Scientific Corporation
KeyCorp
Keystone Automotive Industries
Keystone Foods, LLC
Kforce Inc.
Kiddie Kandids
KIK Custom Products
Kimberly-Clark Corporation
Kindred Healthcare, Inc.
Klein Tools, Inc.
Knight
Knowledge Learning Corporation
Kohler Company
Kohl's Department Stores
Konecranes, Inc.
Kyocera America, Inc.
L.L. Bean, Inc.
Laboratory Corporation of America
Lancaster General
Lance, Inc.
Land O'Lakes, Inc.
LandAmerica Financial Group, Inc.
LANXESS Corporation US
Latham & Watkins LLP
Laureate Education, Inc.
Laureate Education, Inc. - Laureate Online Education
Leatherman Tool Group, Inc.
Legacy Health System
Legal & General America, Inc.
Lehigh Valley Hospital and Health Network
Lennox International, Inc.
Leprino Foods Company
Leupold & Stevens, Inc.
Level 3 Communications
LG Electronics USA, Inc.
LGE MobileComm USA
Liberty Mutual Group
LifeBridge Health - Levindale Hebrew Geriatric
LifeBridge Health - Sinai Hospital of Baltimore
Limited Brands, Inc.
LINAK U.S. Inc.
Linens 'n Things, Inc.
Link-Belt Construction Equipment Company
Liz Claiborne, Inc.
Loews Corporation
Logan's Roadhouse
LORD Corporation
Lorillard Tobacco Company
Los Alamos National Laboratory
Los Angeles Community College District
Los Angeles Unified School District
Louisiana Legislative Auditor
Louisville Regional Airport Authority
Lower Colorado River Authority
Luxottica Retail US
M&T Bank Corporation
Macy's, Inc.
Magellan Health Services
Magellan Midstream Holdings, LP
Magellan Midstream Holdings, LP - Pipeline Operations
Magellan Midstream Holdings, LP - Transportation
Main Line Health, Inc.
Main Street America Group
Malcolm Pirnie, Inc.
Mann+Hummel Advanced Filtration Concepts, Inc.
Mannatech, Inc.
Manpower, Inc.
Maricopa Integrated Health Systems
Markem-Imaje
Marriott International
Mars North America
Mars North America - Mars Food US
Marshall & Ilsley Corporation
Marshfield Clinic
Martek Biosciences Corporation
Martha Jefferson Hospital
Mary Kay, Inc.
Maryland Procurement Office
Masco Corporation
Massachusetts Institute of Technology
MassMutual Life Insurance Company
Mattel, Inc.
Mayo Foundation
McDonald's Corporation
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

MCG Health
McKesson Corporation
MDU Resources
MeadWestvaco Corporation
Mecklenburg County Government
Medco Health Solutions, Inc.
Media General
MedPlus, Inc.
Medrad, Inc.
MedStar Health
Meeting Consultants, Inc.
Memorial Hermann
Mercedes-Benz USA
Mercury Insurance Group
Metal Technologies, Inc.
Metaldyne
MetalTek International
Metavante Corporation
Methodist Health System
MetLife
Metropolitan Atlanta Rapid Transit Authority (MARTA)
Metropolitan Transit Authority
MFS Investment Management
MGA Entertainment
MGE Energy
Michael Baker Corporation
Michaels Stores, Inc.
Michelin North America, Inc.
Midwest Airlines, Inc.
Millbrook Partners
Miller Brewing Company
Milliken & Company
Mills-Peninsula Health Services
Mine Safety Appliances Company
Mirant Corporation
Mitsubishi Motors North America
Modern Woodmen of America
Molex
MoneyGram International, Inc.
Morgan, Lewis & Bockius LLP
Morrison & Foerster, LLP
Mortgage Guaranty Insurance Corporation
Moses Cone Health System
Motion Picture Industry Pension & Health Plans (MPIPHP)
Motorists Insurance Group
MTS Systems Corporation
Mueller Water Products
Munich Reinsurance America, Inc.
Mutual of Enumclaw Insurance Company
Mutual of Omaha
Nash Finch Company
National Association of Home Builders
National Church Residences
National Futures Association
National Rural Telecommunications Cooperative
National Rural Utilities Cooperative Finance Corporation (NRUCFC)
National-Louis University
Nature's Sunshine Products
Nautilus, Inc.
Navarre Corporation
Navy Federal Credit Union
NCCI Holdings, Inc.
NCO Financial Systems, Inc.
Neiman Marcus Group
Nelnet, Inc.
Nestlé USA, Inc.
New York ISO
New York Life Insurance Company
New York Power Authority
New York Presbyterian Hospital
New York State Catholic Health Plan, d/b/a Fidelis Care New York
NewPage Corporation
Nexen Petroleum USA, Inc.
Nicor
Nike, Inc.
North Carolina Baptist Hospital
North Memorial Health Care
Northeast Georgia Health System, Inc.
Northeast Health
Northeast Utilities
Northern Arizona University
NorthWestern Energy
Northwestern Mutual
Northwestern University
Novant Health, Inc.
Novartis Animal Health US, Inc.
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Novartis US - CIBA Vision Corporation
Novo Nordisk Inc.
NRG Energy
NSK Americas
NSTAR
Nutricia North America
NW Natural
NYU Medical Center
Oakland County Government
Oakwood Healthcare, Inc.
Oberg Industries, Inc.
Océ Business Services
OfficeMax Incorporated
OGE Energy
Oglethorpe Power Corporation
Ohio Police and Fire Pension Fund
OhioHealth
Old Dominion Electric Cooperative
Old Dominion University Research Foundation
Omaha Public Power
Omya Industries
OneAmerica Financial Partners, Inc.
OneBeacon Insurance
ONEOK, Inc.
Operator
Opus Corporation
Orange County Government
Orange County Public Schools
Orange County's Credit Union
Orbital Sciences
Orica USA Inc.
Orrick, Herrington & Sutcliffe, LLP
OSI Industries, LLC
Otter Tail
Our Lady of the Lake Regional Medical Center
Owens Corning
PACCAR
PACCESS, LLC
Pacific Gas & Electric
Pacific Northwest National Laboratory
PacifiCorp
Packaging Corporation of America
PAETEC
Palos Community Hospital
Panduit Corporation
Papa John's International, Inc.
Park Nicollet Health Services
Parkland Health & Hospital System
Parkview Health
Parkway Corporation
Parsons Child & Family Center
Partner Reinsurance Company of the U.S.
Pearson Education
Penn State Hershey Medical Center
Pentair, Inc.
Pepco Holdings, Inc.
Pernod Ricard USA
Perot Systems Corporation
PETCO Animal Supplies, Inc.
Pharmaceutical Product Development, Inc.
Pharmavite, LLC
PHH Arval
Phillips-Van Heusen Corporation
Phoenix Children's Hospital
Phoenix Companies
PHOENIX Process Equipment Company
Piaggio Group Americas
Pinnacle West Capital
Pioneer Hi-Bred International
Pioneer Natural Resources USA, Inc.
Pitney Bowes, Inc.
PJM Interconnection
Plains Exploration & Production Company
Plante & Moran, PLLC
Plum Creek Timber Company, Inc.
PNC Financial Services Group, Inc.
PNM Resources
Policy Studies Inc.
PolyOne Corporation
Port Authority of New York & New Jersey
Port of Portland
Port of Seattle
Portland General Electric
PPL Corporation
Premera BlueCross
Premier Manufacturing Support Services, Inc.
Pressure Chemical Co.
PricewaterhouseCoopers
Pride International
Prime Therapeutics LLC
Principal Financial Group
Priority Health
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Progress Energy
Progressive Corporation
Protection One
Protective Life Corporation
Providence Health System in Oregon
Prudential Financial, Inc.
PSC
Public Company Accounting Oversight Board
Public Service Enterprise
Publix Super Markets, Inc.
Puget Energy
Pulmuone Wildwood, Inc.
Pulte Homes, Inc.
QBE Regional Insurance
QSC Audio Products, LLC
Qualcomm, Inc.
Quest Diagnostics
Questar Corporation
Quintiles
Qwest Communications International, Inc.
R.H. Donnelley, Inc.
Rabobank, N.A.
Rackspace IT Hosting
Ralcorp Holdings, Inc.
Raley's
Raymond James Financial
RBC Bank
RBC Wealth Management
Reader's Digest Association
Reckitt Benckiser, Inc.
Recreational Equipment, Inc.
Redcats USA
Reed Construction Data
Reeves Brothers, Inc.
Regency Centers
Regions Financial Corporation
Reliant Energy
Reliant Resources
Renaissance Learning, Inc.
Republic Underwriters Insurance Company
Retail Ventures Services, Inc. - Filene's Basement
Rexam Plastic Sector U.S.
Reynolds American, Inc.
Rich Products Corporation
Rio Tinto plc US
Rite Aid Corporation
RLI Insurance Company
Robert Bosch LLC
Robins, Kaplan, Miller & Ciresi, LLP
Roche Diagnostics US
Rockwell Automation, Inc.
Rockwell Collins
Rogers Corporation
Rosetta Stone, Inc.
Ross Stores, Inc.
Roundy's Supermarkets, Inc.
RR Donnelley & Sons
RREEF
RSC Equipment Rental
RSM McGladrey
Rush University Medical Center
Russell Reynolds, Associates
Ryder Systems, Inc.
S&C Electric Company
S. C. Johnson & Son, Inc.
Sabre Holdings Corporation
SAE International
Safeco Corporation
Safety-Kleen Systems, Inc.
SAIF Corporation
Saint Agnes Medical Center
Saint Joseph Health System
Saint Luke's Health System
Saint Raphael Healthcare System
Sallie Mae
Salt River Project
Sam Levin, Inc.
Samson Investment Company
San Antonio Federal Credit Union
San Antonio Water System
San Diego County Regional Airport Authority
Sanmina-SCI Corporation
Sanofi-Aventis US
Sara Lee Corporation
Sauer-Danfoss
Save the Children Federation, Inc.
SAVVIS, Inc.
SBA Network Services, Inc.
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

SCANA Corporation
SCF Arizona
SCF Arizona - Premier
Schlumberger Oilfield Services
Schneider Electric/Square D Company
Schneider National, Inc.
Schnitzer Steel Industries, Inc.
Scholle Corporation
Schott Solar, Inc.
Scott and White Hospital
SCS Engineers
Sea Star Line, LLC
Securian Financial Group
Securitas Security Services, USA
Selective Insurance Company of America
Seminole Energy Services
Sempra Energy
Sensata Technologies
Sentara Healthcare
Sentry Insurance
Serco NA
Sharp HealthCare
Shearman & Sterling LLP
Shure Incorporated
Sidley Austin, LLP
Simon Property Group
Sinclair Broadcast Group, Inc.
SMC Corporation of America
SMSC Gaming Enterprises
Society of Manufacturing Engineers
Sodexho USA
Southeastern Freight Lines
Southern California Regional Rail Authority
Southern Company
Southern States Cooperative
Southern Union Company
Southwest Airlines
Spartan Stores, Inc.
Spectra Energy
Spectrum Health System
Sprint
SSM Health Care St. Louis
St. Elizabeth Health System
St. Jude Children's Research Hospital
St. Vincent Health
Stamford Hospital
StanCorp Financial Group
Stanford University
Stantec Inc.
Starbucks Coffee Company
Starwood Vacation Ownership
State Auto Insurance Company
State Farm Insurance
State of Indiana
State of Nebraska Department of Administrative Services, Office of the CIO
State of North Carolina
State Personnel Administration (formerly Georgia Merit System)
State Teachers Retirement System of Ohio
Steelcase, Inc.
STG, Inc.
STP Nuclear Operating
Straumann USA
Stream International
Stryker Corporation
Subaru of America, Inc.
Subway Franchisee Advertising Fund Trust
SUEZ Energy North America, Inc.
Summa Health System
Sun Life Financial (US)
Sunoco, Inc.
Sunrise Hospital and Medical Center
Sunsweet Growers, Inc.
SunTrust Banks, Inc.
Superior Essex, Inc.
SuperValu
SureWest Communications
Sutter Health
Swarthmore College
Swedish Health Services
Sykes Enterprises, Incorporated
Symcor
Symetra Financial
Syniverse Technologies
Synovus Financial Corporation
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

T. Rowe Price
Targa Resources, Inc.
TD Ameritrade Holding Corporation
TD Banknorth, Inc.
Technology Credit Union
TECO Energy, Inc.
Telerx Marketing, Inc.
TeleTech Holdings, Inc.
Tellabs
Temple-Inland
Tenaris, Inc. USA
Tenet Healthcare Corporation
Tennant Company
Tennessee Valley Authority
Tesoro Corporation
Texas Health Resources - Presbyterian Hospital of Allen
Texas Health Resources - Presbyterian Village North
Texas Industries, Inc.
Texas Mutual Insurance Company
Texon, LP
Textainer
Textron, Inc.
The Capital Group Companies
The Children's Hospital of Philadelphia
The Children's Mercy Hospital
The Chronicle of Higher Education
The Chubb Corporation
The CNA Corporation
The Coca-Cola Company
The Decurion Corporation
The Doe Run Company
The E. W. Scripps Company
The Employers Association
The Finish Line, Inc.
The Florida Aquarium, Inc.
The Ford Foundation
The Frost National Bank
The Golden 1 Credit Union
The Guardian Life Insurance Company of America
The Hanover Insurance Group, Inc.
The Hartford Financial Services Group, Inc.
The Hershey Company
The Hertz Corporation
The Irvine Company
The Johns Hopkins Hospital
The Joint Commission
The Keane Organization
The Kroger Company
The Longaberger Company
The Methodist Hospital System
The Midland Company
The MITRE Corporation
The Nielsen Company
The NORDAM Group
The Ohio State University
The Regence Group
The Schwan Food Company
The Seattle Times Company
The ServiceMaster Company
The Sherwin-Williams Company
The Sports Authority
The Sundt Companies, Inc.
The Supreme Court of Ohio
The TJX Companies, Inc.
The Toro Company
The Travelers Companies, Inc.
The Turner Corporation
The University of Arizona
The University of Chicago
The University of Chicago Medical Center
The University of Kansas Hospital
The University of New Mexico
The University of Texas Health Science Center at Houston
The University of Texas M. D. Anderson Cancer Center
The University of Texas Medical Branch
The University of Texas Southwestern Medical Center
The Vanguard Group, Inc.
The W.C. Bradley Co.
The Warranty Group, Inc.
The Weitz Company, LLC
The Williams Companies, Inc.
The Yankee Candle Company, Inc.
Thrivent Financial for Lutherans
TIAA-CREF
Timberland Company
Time Warner Telecom, Inc.
Time Warner, Inc.
Title Resource Group
TIW Corporation
T-Mobile USA
Toll Brothers
Toshiba America Business Solutions, Inc.
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

Toshiba America Medical Systems, Inc.
Totem Ocean Trailer Express, Inc.
Toyota Industrial Equipment Manufacturing, Inc.
Trane
TransCanada
TransUnion, LLC
Travis County
Trebol USA, LLC
Trelleborg Automotive Americas
Trelleborg Sealing Solutions U.S., Inc.
Trinity Health
TriWest Healthcare Alliance
Trust Company of America
TSYS Core
Turner Broadcasting System, Inc.
Tyco Electronics
U.S. Cellular®
U.S. Foodservice
UAP Holding
UIL Holdings
Underwriters Laboratories, Inc.
Unified Grocers
Unilever U.S.
UniSource Energy
UNITECH Solutions
United Airlines
United Industries
United Stationers Supply Company
United Water
United Western Bancorp, Inc.
United Western Bancorp, Inc. - United Western Bank
UnitedHealth Group
Unitil
Unitrin Career Agency Companies
Universal Health Services, Inc.
Universal Technical Institute
University of Central Florida
University of Central Missouri
University of Colorado Hospital
University of Houston
University of Illinois at Chicago
University of Louisville
University of Maryland Medical Center
University of Michigan
University of Minnesota
University of Missouri
University of New Mexico Hospitals
University of Pennsylvania
University of Pittsburgh
University of Virginia Health System
University Physicians Healthcare
University Physicians Healthcare - UPH Hospital at Kino Campus
UNUM Group
UPM-Kymmene, Inc.
UPM-Kymmene, Inc. - Blandin Paper Company
Uponor, Inc.
US Airways
US Bancorp
US Oncology, Inc.
US Xpress
USANA Health Sciences
USG Corporation
USG Corporation - L&W Supply
USGA
UST
Utah Transit Authority
Vail Mountain, Inc.
Valero Energy Corporation
Valmont Industries, Inc.
ValueOptions
Vanderbilt University
Vectren Corporation
Ventura Foods, LLC
VeriSign, Inc.
Vermeer Manufacturing Company
Videojet Technologies, Inc.
 
 
 

 
Appendix A
Addendum to response #4 – For illustrative purposes only

ViewSonic Corporation
Vinson & Elkins, LLP
Virginia Credit Union, Inc.
Virginia United Methodist Homes, Inc.
Visiting Nurse Service of New York
Vistar Corporation
Visteon Corporation
VITAS Healthcare Corporation
Volvo Financial Services
Vonage Holdings Corporation
W. R. Grace
W.L. Gore & Associates, Inc.
Wachovia Corporation
Wackenhut Services, Inc. - Savannah River Site
Waddell & Reed
Waggener Edstrom Worldwide
Wake County Government
Walt Disney Parks & Resorts, LLC
Washington Hospital Center
Washington Metropolitan Area Transit Authority
Washington Mutual, Inc.
Washington Savannah River Company
Washington Suburban Sanitary Commission
Waste Management
Watkins Manufacturing
Wayne Memorial Hospital
Webster Financial Corporation
Wegmans Food Markets, Inc.
Weil, Gotshal & Manges, LLP
WellCare Health Plans
WellPoint, Inc.
Wells' Dairy, Inc.
Wells Fargo & Company
WellSpan Health
Weltman, Weinberg & Reis Co., LPA
Wendy's International, Inc.
West Penn Allegheny Health System - Allegheny General Hospital
West Penn Allegheny Health System - Alle-Kiski Medical Center
West Penn Allegheny Health System - Canonsburg General Hospital
West Penn Allegheny Health System - The Western Pennsylvania Hospital
Westar Energy
Western & Southern Financial Group
Western Digital
Western Union
Westinghouse Electric Company
Weston Solutions, Inc.
W-H Energy Services, Inc.
Wheaton College
Wheaton Franciscan Healthcare
Whip Mix Corporation
Whirlpool Corporation
White Electronic Designs Corporation
Whole Foods Market
William Blair & Company, LLC
William Marsh Rice University
Williams Companies
Wilmer Cutler Pickering Hale & Dorr
Winn-Dixie Stores, Inc.
Winston Industries, Inc.
Wisconsin Court System
Wisconsin Energy
Wisconsin Physicians Service
Wm. Wrigley Jr. Company
Wolf Creek Nuclear
Wolters Kluwer NA
World Vision USA
Worthington Industries
WPP
WPP - Millward Brown
Wright Express Corporation
Wyndham Worldwide
Xcel Energy, Inc.
XL America
XTO Energy, Inc.
Yale University
Yale-New Haven Health System
Yamaha Corporation of America
Zale Corporation
Zions Bancorporation
Zoological Society of Philadelphia
Zurich North America