SEC Comment Letter for Cencora, Inc. (COR) (CIK 0001140859) (COR) — Mar 16, 2006
Cencora, Inc. (COR) (CIK 0001140859)
Date: March 16, 2006 · CIK: 0001140859 · Accession: 0000000000-06-012765
AI Filing Summary & Sentiment
Letter
Mail Stop 6010 Via Facsimile and U.S. Mail March 16, 2006 Mr. Michael D. DiCandilo Chief Financial Officer AmerisourceBergen Corporation 1300 Morris Drive Chesterbrook, PA 19087-5594
Re: AmerisourceBergen Corporation Form 10-K for September 30, 2004 Form 10-Q for June 30, 2005 File No. 1-16671
Dear Mr. DiCandilo:
We have reviewed your letter of respons e dated February 6, 2006 and have the following comments. In our comments, we ask you to provide us with information so we may better understand your disclosure. After reviewing this inform ation, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for September 30, 2004
1. You state that in drop-ship transactio ns, the customer typically approaches the supplier first if there is a conc ern regarding accep tability of the products purchased. Be more specific about what “typically” means. It would appear that you are not responsible for fulfillment on those sales. If you disagree, please explain. 2. In response one you state that in cro ss-dock transactions, the customer will typically approach you regarding any c oncerns. More fully explain to us
Michae l D. DiCandilo AmerisourceBergen Corporation March 16, 2006 Page 2
those situations where the custom er approaches the supplier rather than you in cross-dock transactions and explain why the supplier is not responsib le for fulfillm ent on those s ales. 3. In response two you state “In instan ces where a su pplier accep ts orders from our custom er directly, we will f acilitate the process ing of such order s as necessary .” Please tell us if you, in fact, actually pro cess such orders. Tell us if this sentenc e applies to drop-shipm ents or cross-dock transactions, or both. In all cases wh ere a supp lier accep ts ord ers from a custom er directly explain why you are responsible for fulfillm ent in those transactions rather than the supplier.
You m ay contact L isa Vanjoske, Assist ant Chief Accountant, at 202-551-3614 if you have questions regarding the comments. In this regard, do not hesitate to contact m e, at (202) 551-3679.
S incerely,
Jim B. Rosenberg Senior Assistant Chief Accountant
Show Raw Text
Mail Stop 6010
Via Facsimile and U.S. Mail
March 16, 2006
Mr. Michael D. DiCandilo
Chief Financial Officer
AmerisourceBergen Corporation
1300 Morris Drive
Chesterbrook, PA 19087-5594
Re: AmerisourceBergen Corporation
Form 10-K for September 30, 2004
Form 10-Q for June 30, 2005
File No. 1-16671
Dear Mr. DiCandilo:
We have reviewed your letter of respons e dated February 6, 2006 and have the
following comments. In our comments, we ask you to provide us with information so we
may better understand your disclosure. After reviewing this inform ation, we may raise
additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing. We look forward to working with you in these respects. We
welcome any questions you may have about our comments or any other aspect of our
review. Feel free to call us at the telephone numbers listed at the end of this letter.
Form 10-K for September 30, 2004
1. You state that in drop-ship transactio ns, the customer typically approaches
the supplier first if there is a conc ern regarding accep tability of the
products purchased. Be more specific about what “typically” means. It
would appear that you are not responsible for fulfillment on those sales. If you disagree, please explain.
2. In response one you state that in cro ss-dock transactions, the customer will
typically approach you regarding any c oncerns. More fully explain to us
Michae l D. DiCandilo
AmerisourceBergen Corporation
March 16, 2006
Page 2
those situations where the custom er approaches the supplier rather than
you in cross-dock transactions and explain why the supplier is not
responsib le for fulfillm ent on those s ales.
3. In response two you state “In instan ces where a su pplier accep ts orders
from our custom er directly, we will f acilitate the process ing of such order s
as necessary .” Please tell us if you, in fact, actually pro cess such orders.
Tell us if this sentenc e applies to drop-shipm ents or cross-dock
transactions, or both. In all cases wh ere a supp lier accep ts ord ers from a
custom er directly explain why you are responsible for fulfillm ent in those
transactions rather than the supplier.
You m ay contact L isa Vanjoske, Assist ant Chief Accountant, at 202-551-3614 if
you have questions regarding the comments. In this regard, do not hesitate to contact m e,
at (202) 551-3679.
S incerely,
Jim B. Rosenberg
Senior Assistant Chief Accountant