SecProbe.io

March 20, 2012
 Via E-mail

Tim G. Guttman Executive Vice President, Controller and    Acting Chief Fi nancial Officer
AmerisourceBergen Corporation 1300 Morris Drive Chesterbrook, PA 19087-5594
Re: AmerisourceBergen Corporation
 Form 10-K for the Year Ended September 30, 2011
Filed November 22, 2011 File No. 001-16671

Dear Mr. Guttman:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.
             Form 10-K for the Year Ended September 30, 2011

 Item 1. Business, page 1

 1. We note your disclosure on page 3 that  your specialty pharmaceuticals business
represented $15.5 billion in revenue for fiscal  year 2011.  We also note your disclosure
on page 21 that your specialty group provide s pharmaceutical distribution and other
services primarily to physicians who specialize in a variety of disease states, especially
oncology as well as third party logistics and outcomes resear ch, and other services for
biotechnology and other pharmaceutical manufacturer s.  Please advise us with a view to
disclosure of the factors you consider when determining what products and services are
deemed  “Specialty.”  In so doing, please clarify whether your de finition of specialty is
based on an industry, regulatory or  other standard.  Also, please  advise us to the best of

Tim G. Guttman AmerisourceBergen Corporation March 20, 2012 Page 2

 your knowledge if your use of the term, specialty, is the same as or comparable to what is
used by other pharmaceutical distribution companies.
 Notes to Consolidated Financial Statements, page 41

 Note 14. Business Segment Information, page 63

 2. We note your disclosure that the Amerisou rceBergen Drug Corporation (“ABDC”) and
AmerisourceBergen Specialty Group (“ABSG”)  operating segments each operate in a
high volume and low margin environment and, as  a result, their economic characteristics
are similar.  We further note your discussion of  operating results in your periodic reports,
earnings releases on Forms 8-K and earnings conference call transcripts; and statements
in your earnings conference call transcripts that specialty is one of the two primary
growth drivers from which you continue to bene fit.  It appears to us that your operating
segments may have dissimilar gross margins a nd sales trends.  Please provide us with a
robust analysis to support your conclusion th at your operating segments have similar
economic characteristics, includ ing your consideration of gr oss margins and sales trends
of each operating segment.  Refer to AS C 280-10-50-11 and ASC 280-10-55-7A through
55-7C.

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 comments, please provi de 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.

Tim G. Guttman AmerisourceBergen Corporation March 20, 2012 Page 3

 You may contact Brian McAllister at (202) 551-3341 or John Archfield at (202) 551-
3315 if you have questions regarding comments on th e financial statements and related matters.
Please contact Adam Turk at (202) 5 51-3657 or James Lopez at (202) 551-3536
with any other questions.
Sincerely,  /s/Tia L. Jenkins

    Tia L. Jenkins         Senior Assistant Chief Accountant
Office of Beverages, Apparel, and Mining