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SEC Response Letter

 GENERAL BUSINESS: 1-631-843-5500

FAX: 1-631-843-5680

www.henryschein.com

 March 24, 2016

Mr. Rufus Decker

 United States Securities and Exchange
Commission

 Division of Corporate Finance

 100 F Street N.E.

 Washington, D.C. 20549

 Re: Henry Schein, Inc.

Form 10-K for the Fiscal Year Ended December 26, 2015

Filed February 10, 2016

 File No. 0-27078

Dear Mr. Decker:

 We acknowledge receipt of your letter
dated February 26, 2016 regarding your review of the above referenced filing. We bring the following to your attention as relevant background when assessing our response.

Each year, in preparing its financial statements, the Company’s management has considered the aggregation criteria prescribed by ASC 280-10-50-11 and ASC
280-10-55-7A through 55-7C, and has concluded that the dental, animal health and medical operating segments (“operating segments”) continue to share similar economic characteristics, are expected to have similar future prospects, and have
similar operating characteristics. Therefore, it continues to be appropriate to aggregate these operating segments into our health care distribution reportable segment for the years included in the above-referenced Form 10-K.

As discussed in our letter to the Commission dated May 2, 2011, although we have considered other financial measures, we have always judged operating
margin (not gross margin) to be the best indicator of economic characteristics when evaluating the aggregation criteria given our specific facts and circumstances. We continue to analyze our businesses internally based principally on operating
income because, as discussed in Note 1 to our financial statements, costs related to purchasing, receiving, inspections, warehousing, internal inventory transfers and other costs of our distribution network are included in selling, general and
administrative expenses, as opposed to cost of goods sold, along with other operating costs. Additionally, products with lower gross profit margins generally have lower selling, general and administrative expenses, which result in more similar
operating margins. Consequently, operating margin is the best comparative measure and best demonstrates the similar overall economic characteristics of our operating segments. Operating income also serves as a primary component in determining the
business segments leaders’ incentive bonus compensation. Additionally, when we evaluate acquisition targets, we focus on the target’s operating income, operating margin and return on investment.

As indicated in Exhibit A-3, operating income margins are relatively aligned and stable across our operating segments. As we continue to introduce pricing and
cost-containment strategies, we

expect the operating margins to improve in the future and to converge more closely. The differences in operating margins among the operating segments are not significant and are not due to
differences in economic characteristics. The dental operating segment has been able to achieve higher operating margins due primarily to its relative product and customer mix. We offer a wide range of common products across the dental, medical, and
animal health operating segments, but the mix of those products varies. For example, the contribution of pharmaceutical products to revenues is greater in the medical and animal health businesses than in dental. These sales generally result in lower
operating margins. Conversely, the dental business currently gets a more significant portion of its sales from private label products as compared to our medical and animal health businesses. Sales of our private label products often achieve
operating margins that exceed our overall average operating margin. Our current marketing plans reflect increased efforts to grow private label sales in the animal health and medical operating segments in the near future. Additionally, differences
in customer mix contribute to the variances in the respective operating margins. Large-group customers tend to have greater purchasing power resulting in lower operating margins. The dental business has relatively fewer large-group customers than
the medical and animal health operating segments, which benefits its operating margin. However, each of our operating segments, including dental, is experiencing growth in large-group and corporate customers throughout the world, which will
contribute to greater convergence of the operating income margins in the future.

 Management also focuses on local currency internal sales growth when
assessing the operating performance of the dental, animal health and medical operating segments. Historically, these three operating segments have experienced similar growth rates on a local currency internal growth basis. We believe this is
indicative of the similar market conditions in which the operating segments operate globally, including the demands and requirements of their customers. We fully expect the similarities of these market conditions throughout the world to continue in
the foreseeable future, which will result in a continuation of similar growth rates by the three operating segments in the future.

 We sell a broad range
of products, substantially all of which may be categorized as health care products. Numerous product groups are offered to customers across all of our operating segments, including infection control products, surgical products, examination gloves,
wound closure and wound care products, disposable exam room products, pharmaceutical products, basic equipment and office supplies among others. Given the large number and wide range of common product offerings, we do not manage our business by
product and service categories. Product-related functions, such as procurement and warehousing, are managed centrally. We also have a centralized group that manages our dental, animal health and medical private label products.

Across all of our operating segments, our customer base has several common characteristics. Substantially all of our customers are healthcare providers,
including office-based practitioners, health clinics, and private and public institutions. Our customers tend to place relatively small orders (in 2015, our average order sizes were $359 for animal health customers, $491 for dental customers, and
$629 for medical customers) with frequent orders being placed along with a requirement for quick delivery due to limited storage capacities at their practice locations. Our average order size has remained relatively consistent over the last several
years and is expected to remain so for the foreseeable future. Although we have a sales force that is distinct to each

 2

operating segment, including sales specialists who focus on specific product categories, our sales approach, including field sales consultants, telesales representatives, catalogs, etc., is
common to all our customers. Our customer service functions (delivery status and assistance, customer queries, etc.) are provided by a single group of people who support all of our operating segments.

Across each of the operating segments, market dynamics are affecting our customer base in similar ways and, as a result, each segment is experiencing similar
changes. Dental, animal health and medical practitioners are increasingly combining their professional practices in an effort to become more efficient. As these practices grow in size, they are concentrating their purchases of goods and services
with fewer and larger suppliers. Furthermore, they are becoming increasingly reliant on larger suppliers to identify cost efficiencies as they combine their practices.

Substantially all products within our healthcare distribution reportable segment are distributed via third-party freight companies (i.e., United Parcel
Service, etc.) from our warehouses. Within our warehouses, products are stored based on cube size, frequency of ordering, and any special handling requirements, such as refrigeration, and are not segregated by operating segment. As indicated above,
order sizes are similar among our customers in each of the operating segments, thus small parcel delivery is the typical form of distribution.

 To
effectively manage the distribution of our products and services in all of our operating segments, the Company maintains global support functions including, but not limited to distribution, inventory control, transportation, purchasing, customer
service, web design, information systems, human resources, regulatory, some financial operations (credit, payroll, invoice processing, etc.), treasury, insurance, legal, tax, financial planning, and internal audit. In the United States, our dental
and medical operating segments have a shared warehousing infrastructure and we are evaluating the inclusion of animal health products within this warehousing infrastructure. Internationally, it is common for our animal health operating segment to
share the same warehousing infrastructure as our dental and medical operating segments.

 In summary, we believe the economic and operating characteristics
of these operating segments support the aggregation of such segments as one reportable segment. The similarities of these characteristics enable us to use common business functions to execute and manage the segments’ operations. These
characteristics are consistent with the aggregation criteria in ASC 280-10-50-11. Given these similarities, users of our financial statements are able to understand the performance of our health care distribution segment, assess its prospects for
future net cash flows and make informed judgments about our Company as a whole.

 With reference to the specific comments in your letter dated
February 26, 2016, please see the following responses corresponding to the numbered comments in your letter.

 3

 Form 10-K for the Fiscal Year Ended December 26, 2015

Notes to Consolidated Financial Statements

 Note 15.
Segment and Geographic Data, page 96

1.
Almost 97% of your total sales in fiscal 2015 were from the health care distribution reportable segment. Each of the three operating segments (dental, animal health and medical) aggregated into this reportable
segment represented 19% or more of your total sales in fiscal 2015. Your disclosures of sales by operating segment for each of the last five fiscal years on page 36 and your discussions of changes in sales on pages 46 and 49 indicate that each of
these operating segments may have experienced significant variances in sales trends in recent years. In addition, based upon the North America and International sales information disclosed in Exhibit A of the Form 8-K filed February 10, 2016,
it appears each of these operating segments have varying proportions of sales from foreign countries. Please explain in detail how you concluded each of these operating segments have similar economic characteristics. For each operating segment,
please also provide us with your historical and projected sales, gross profit, operating income and measure of segment profitability. Please show each profit measure in dollars and as a percentage of sales. Please also show both the dollar and
percentage changes from period to period in your analysis. Please include detailed explanations for any apparent differences in economic characteristics and trends for a given operating segment when compared to another operating segment for a given
period or over several periods. Please also explain why each of these differences would not be considered an indication of differences in economic characteristics between the operating segments and your basis for concluding that aggregation is
appropriate. Refer to the guidance outlined in ASC 280-10-50-11 and ASC 280-10-55-7A through 55-7C.

 With respect to your request that
we provide historical and projected sales, gross profit, operating income and measure of segment profitability for our dental, animal health and medical operating segments for each of the last five years, we refer you to Exhibits A-1 for sales,
Exhibit A-2 for gross profit, and Exhibit A-3 for operating income. We are supplementally providing Exhibits A-1, A-2 and A-3 to you pursuant to the procedures set forth in 17 C.F.R. §200.83 and Rule 12b-4 under the Securities Exchange Act of
1934, as amended. Exhibits A-1, A-2 and A-3, and the information contained therein, are nonpublic and confidential and remain the property of the Company. We hereby request that Exhibits A-1, A-2 and A-3, and all copies thereof, be
returned to the undersigned promptly following completion of your review thereof.

 Net Sales

The following tables illustrate the components of total annual sales growth for each of the operating segments for the years 2011-2015, segregating the effect
of acquisitions, effect of foreign exchange, and local currency internal growth.

 4

Total Sales Growth

2015

2014

2013

2012

2011

 Dental

-1.9
%

7.7
%

4.7
%

0.2
%

7.9
%

 Animal Heath

0.8
%

11.5
%

12.0
%

15.5
%

30.8
%

 Medical

18.9
%

6.1
%

5.3
%

3.8
%

9.5
%

 Healthcare distribution

2.5
%

8.5
%

6.7
%

4.6
%

13.0
%

Effect of Acquisitions

2015

2014

2013

2012

2011

 Dental

0.6
%

4.9
%

2.2
%

1.2
%

1.0
%

 Animal Heath

6.5
%

4.9
%

6.8
%

9.1
%

18.0
%

 Medical

7.5
%

0.1
%

0.5
%

0.9
%

1.4
%

 Healthcare distribution

3.5
%

4.0
%

3.1
%

3.0
%

4.6
%

Effect of Foreign Exchange

2015

2014

2013

2012

2011

 Dental

-6.9
%

-0.5
%

0.4
%

-2.3
%

2.4
%

 Animal Heath

-7.6
%

0.3
%

-0.3
%

-2.2
%

4.6
%

 Medical

-0.8
%

0.1
%

0.2
%

-0.4
%

0.3
%

 Healthcare distribution

-6.1
%

-0.1
%

0.1
%

-1.9
%

2.5
%

Local Currency Internal Growth

2015

2014

2013

2012

2011

 Dental

4.4
%

3.3
%

2.1
%

1.3
%

4.5
%

 Animal Heath

1.9
%

6.3
%

5.5
%

8.6
%

8.2
%

 Medical

12.2
%

5.9
%

4.6
%

3.3
%

7.8
%

 Healthcare distribution

5.1
%

4.6
%

3.5
%

3.5
%

5.9
%

 As indicated above, the annual growth rates of net sales in each of the operating segments may be materially influenced by the
effects of newly acquired businesses. Our acquisition strategy includes acquiring businesses and entering into joint ventures complementary to ours that will provide, among other things, additional sales to be channeled through our existing
distribution infrastructure, access to additional product lines and field sales consultants and an opportunity to further expand into new geographic markets. During the fiscal years 2011 through 2015, each of our operating segments has experienced
net sales growth through the completion of acquisitions. Given the sporadic frequency and size of acquisitions, any detailed explanations for apparent differences in sales trends for and among the operating segments should exclude the effects of
acquisitions.

 5

 Also, as indicated above, the net sales growth in our operating segments may also be influenced by the effects of
changes in foreign currency translation rates. Given that foreign exchange rates largely offset over the long term and have no significant effect on local demand for the Company’s products, the effects of changes in foreign exchange rates on
year-over-year sales should not be considered when analyzing economic performance. Our experience indicates that an operating segment’s long-term economic characteristics are not influenced by changes in foreign exchange rates. We do not
believe the demand for health care products outside the United States is affected when the local currency weakens or strengthens against other currencies.

We note the Commission’s observation that “…it appears each of these operating segments have varying proportions of sales from foreign
countries.” While the operating segments do have varying degrees of international sales as we indicate above, we do not believe this creates any meaningful differences in economic characteristics among the operating segments. Additionally, the
operating segments retain simila