1.	We note your disclosure on page 22 that subsequent to April 28, 2012, you became aware of circumstances that could cause an increase in your allowance for doubtful accounts in an amount between $0 and $2.5 million. Please revise future filings to describe the specific factors impacting collectability and disclose the extent to which your credit risk varies by geographic region.

2.

We note that days sales outstanding increased from 45 days as of April 30, 2011, to 54 days as of April 28, 2012, which you attribute to the “natural volatility that can occur with large projects and the timing of customer payments.” This buildup in accounts receivable had a material adverse impact on your operating cash flows for fiscals 2012 and 2011. We also note that the change in billings in excess of costs and estimated earnings had a material adverse impact on your operating cash flow for fiscal 2012. Please revise future filings to expand your discussion on page 33 regarding the changes in DSO, and billings in excess of costs and estimated earnings, as the current disclosure does not fully explain the variances. Specifically address whether there were any material changes in A/R aging, contractual payment/billing terms, and/or the materiality of customer disagreements, or any other known factors that materially impact these balances. Refer to Item 303(a)(1) of Regulation S-K.

---

3.	On page 33 you disclose days inventory outstanding increased from 41 days as of April 30, 2011, to 53 days as of April 28, 2012. This apparent buildup in inventories adversely impacted your operating cash flow surplus in fiscals 2012 and 2011. In future filings, please explain material variances in the inventory ratio.

4.	You disclose that inventories are reported net of an allowance for excess and obsolete inventory. In future filings, please revise herein to present a rollforward and show the activity in this allowance for the periods presented, or include it within the Schedule II. Refer to Rule 12-09 of Regulation S-X.

5.

We note your disclosure that you are involved in various claims and legal actions arising in the normal course of business, but for which you believe the disposition of these matters, taken as a whole, will not have a material adverse effect on your consolidated financial statements. In future filings, please provide the disclosures required by ASC 450-20-50-1 - 50-2 for probable loss contingencies in which you have recognized an accrual. Please also provide the disclosures required by ASC 450-20-50-3 - 50-8 for reasonably possible losses in excess of accrual. Please ensure your disclosures describe the loss contingency using the terms referenced in ASC 450-20-25. Please note that disclosure of the accrual of probable losses and the disclosure of reasonably possible losses in excess of accruals may be provided on an aggregated basis. To the extent that you have determined that the reasonably possible loss in excess of accrual is immaterial, please disclose that fact.

---

6.

Please explain to us in detail how you determined that the $1.8 million Transportation segment loss reversal (page 18) was appropriately recognized in the July 28, 2012, quarter instead of in the April 28, 2012, quarter. In this regard, we note that the April 28, 2012 Form 10-K was filed midway through the July 28, 2012, quarter. Identify the specific events and circumstances which precipitated the accounting change and how you determined that recognition in the fourth quarter was not required. We may have further comment.

---