November 2, 2010

Mr. Larry Spirgel

Assistant Director

Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Mail Stop 4561

Washington, D.C. 20549

Dear Mr. Spirgel:

This letter is in response to your comments communicated to us in a letter dated October 19, 2010, which was a follow-on request for additional information to our original response to you dated October 14, 2010. Your comments (in bold), along with our responses, are set forth below:

Form 10-K for Fiscal Year Ended December 25, 2009

Financial Statements, page 33

We have performed an analysis under the guidance set forth in Staff Accounting Bulletin No. 99 (“SAB 99”) of the impact of closed branches which qualify for reporting as discontinued operations. Prior to our summary of our SAB 99 analysis, we believe it would be beneficial to highlight our Revenue from services and Income before tax expense trends for the years presented in the Form 10-K for the fiscal year ended December 25, 2009.

We discussed in Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations in the Form 10-K for the fiscal year ended December 25, 2009 that “We continue to face a challenging economic climate with customer spending being negatively impacted by the global recession as well as an increasingly competitive landscape. We experienced a significant decrease in demand for blue-collar staffing during 2009. The recession began in 2008 and continued throughout 2009.” We experienced the economic slowdown starting in 2007. Our Revenue from services (“Revenue”) and Income before tax expense (“Pre-tax income”) declined significantly. In response, we consolidated our operations to preserve profitability. Pre-tax income declined to a nominal 1% of 2009 revenue.

The temporary staffing industry for blue-collar workers is highly cyclical and generally the first to experience a downturn. The severity of the most recent recession significantly impacted our normal trends. Prior to the recession, Pre-tax income was 7% on average for the years 2003 through 2007. As the economy recovers, we expect Pre-tax income to increase.

Our SAB 99 analysis considered both the quantitative and qualitative impacts of the discontinued operations on our consolidated financial statements in conjunction with the above trends. We and the audit committee of our board of directors have concluded, and our auditor concurred, that the discontinued operations were not material to our consolidated financial statements based on the quantitative and qualitative measures within our SAB 99 analysis.

Listed below is a summary of the quantitative factors of our analysis:

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We also considered qualitative factors and summarize as follows:

Based on the quantitative and qualitative factors, we believe that the judgment of a reasonable investor would not have been changed or influenced by the classification of the closed and not consolidated branches as discontinued operations for all years presented in Form 10-K for the year ended December 25, 2009.

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To clarify our position for our current definite-lived intangible assets, we do group customer relationships at the branch level because the majority of the cash flows are identifiable to the branch. Our remaining definite-lived intangible assets, representing trademarks and non-compete agreements, are grouped at the brand level and do not generate cash flows that are attributable to any one branch.

In our October 14, 2010 response we stated that in our next Form 10-K filing we will revise and expand our policy discussion of impairment of long-lived assets. That proposed disclosure is included below together with our revisions that are underlined. The revised disclosure should further clarify our policy and current treatment.

Long-Lived Asset Impairment

Long-lived assets include property and equipment and definite-lived intangible assets. Definite-lived intangible assets consist of customer relationships, tradenames and non-compete agreements. Long-lived assets are tested for impairment whenever events or changes in circumstances indicate that the carrying value of the assets may not be recoverable. The assets are not recoverable if their carrying value is less than the undiscounted cash flows we expect to generate from such assets. If the assets are not deemed to be recoverable, impairment is measured based on the excess of their carrying value over their fair value. Upon indication that the carrying values of the assets may not be recoverable, we recognize an impairment loss. The fair value of the assets is estimated using the discounted future cash flows of the assets. Long-lived assets are grouped at the lowest level at which identifiable cash flows are largely independent when assessing impairment. Our branch assets including property and equipment and customer relationship intangibles are grouped and evaluated at the individual branch level. All other property and equipment and definite-lived intangibles are grouped at either the Brand or Corporate level as appropriate based on the identifiable cash flows. For long-lived assets that are not deemed to be recoverable, we write down to the estimated fair value, which becomes the new cost basis. Considerable management judgment is necessary to estimate future after-tax cash flows, including cash flows from continuing use and terminal value. Accordingly, actual future results could vary from our estimates.

In connection with our response, we acknowledge that:

Please do not hesitate to contact me or Norman Frey at (253) 680-8286 with any questions or further comments you may have regarding this letter.

Chief Financial Officer

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