SEC Comment Letter for Cencora, Inc. (COR) (CIK 0001140859) (COR) — Jan 7, 2011
Cencora, Inc. (COR) (CIK 0001140859)
Date: Jan. 7, 2011 · CIK: 0001140859 · Accession: 0000000000-11-001669
AI Filing Summary & Sentiment
File numbers found in text: 001-16671
Letter
January 7, 2011 Mr. R. David Yost Chief Executive Officer AmerisourceBergen Corp. 1300 Morris Drive Chesterbrook, PA 19087-5594
Re: AmerisourceBergen Corp. Form 10-K for the Fiscal Year Ended September 30, 2010 Filed November 23, 2010 File No. 001-16671
Dear Mr. Yost: We have reviewed your filing and have the fo llowing comment. In our comment, we ask you to provide us with information so we may better understa nd your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to the comment, we may have additional comments. Notes to Consolidated Financial Statements, page 43
Note 14. Business Segment Information, page 66
1. We note that you aggregate your three operating segments into one reportable segment pursuant to FASB ASC 280 due to their simila r economic characteristics. We further note on page 67 that beginning in fiscal 2011, ce rtain specialty service businesses within AmerisourceBergen Specialty Group (“ABSG”) will be combined to form the operations of AmerisourceBergen Consulting Services (“ ABCS”). Please tell us if ABCS will become a new operating and reportable segment in fiscal 2011 and, if not, explain to us your basis under FASB ASC 280 for not pres enting ABCS as a reportable segment.
* * * *
Mr. R. David Yost AmerisourceBergen Corp. January 7, 2011 Page 2
We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment, please provide a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
• staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
• the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States.
You may contact John Archfiel d at (202) 551-3315 or Ryan Milne at (202) 551-3688 if you have questions regarding comments on the fina ncial statements and related matters. Please contact me at (202) 551-3871 with any other questions.
Sincerely,
Tia Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel and Health Care Services
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January 7, 2011 Mr. R. David Yost Chief Executive Officer AmerisourceBergen Corp. 1300 Morris Drive Chesterbrook, PA 19087-5594 Re: AmerisourceBergen Corp. Form 10-K for the Fiscal Year Ended September 30, 2010 Filed November 23, 2010 File No. 001-16671 Dear Mr. Yost: We have reviewed your filing and have the fo llowing comment. In our comment, we ask you to provide us with information so we may better understa nd your disclosure. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to the comment, we may have additional comments. Notes to Consolidated Financial Statements, page 43 Note 14. Business Segment Information, page 66 1. We note that you aggregate your three operating segments into one reportable segment pursuant to FASB ASC 280 due to their simila r economic characteristics. We further note on page 67 that beginning in fiscal 2011, ce rtain specialty service businesses within AmerisourceBergen Specialty Group (“ABSG”) will be combined to form the operations of AmerisourceBergen Consulting Services (“ ABCS”). Please tell us if ABCS will become a new operating and reportable segment in fiscal 2011 and, if not, explain to us your basis under FASB ASC 280 for not pres enting ABCS as a reportable segment. * * * * Mr. R. David Yost AmerisourceBergen Corp. January 7, 2011 Page 2 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure in the filing to be certain that the filing include s the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules requir e. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment, please provide a written statement from the company acknowledging that: • the company is responsible for the adequacy an d accuracy of the disclo sure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and • the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federa l securities laws of the United States. You may contact John Archfiel d at (202) 551-3315 or Ryan Milne at (202) 551-3688 if you have questions regarding comments on the fina ncial statements and related matters. Please contact me at (202) 551-3871 with any other questions. Sincerely, Tia Jenkins Senior Assistant Chief Accountant Office of Beverages, Apparel and Health Care Services