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Mail Stop 3561          February 2, 2010  R. David Yost President and Chief Executive Officer AmerisourceBergen Corporation 1300 Morris Drive Chesterbrook, PA 19087-5594

Re: AmerisourceBergen Corporation
 Form 10-K for Fiscal Ye ar Ended September 30, 2009
Filed November 25, 2009
 File No. 001-16671

Dear Mr. Yost:
 We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  If
you disagree, we will consider your explanation as to why our comment is inapplicable or
a revision is unnecessary.  Please be as deta iled as necessary in your explanation.  In
some comments, we have asked you to provide us with additional information so we may
better understand your disclosure.  Please do so within the time fram e set forth below.
You should comply with the remaining comment s in all future filings, as applicable.
Please confirm in writing that you will do so and also explain to us how you intend to
comply, within the time frame set forth below.   Please understand that after our review of
all of your responses, 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.
 Item 15. Exhibits and Financial Statement Schedules

 1. It appears that you do not in clude exhibits or schedules  to some of your filed
exhibits.  Please see exhibits 10.36, 10.48 and 10.49.  Please provide the missing
schedules with your next Exchange Act filing.

*****

R. David Yost
AmerisourceBergen Corporation February 2, 2010 Page 2
As appropriate, please amend your filings and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ents to expedite our review.  Please furnish
a cover letter with your amendments that keys your responses to our comments and
provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendments and responses to our comments.   We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filings to be certain that  the filings include all information required
under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in
the filing;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.     You may contact John Arch field at (202) 551-3315 or David Walz at (202) 551-
3358 if you have questions regarding comments on the financial statements and related
matters.  Please contact Damon Colbert at  (202) 551-3581 or James Lopez at (202) 551-
3536 with any other questions.
Sincerely,
    John Reynolds
Assistant Director