SecProbe.io

June 20 , 2013

Via E -mail
Steven H. Collis
President and Chief Executive Officer
AmerisourceBergen Corporation
1300 Morris Drive
Chesterbrook, PA 19087

Re: AmerisourceBergen Corporation
 Form 10 -K for the Fiscal Year Ended September 30, 2012
Filed November 27, 2012
Supplemental Response submitted June 14 , 2013
File No. 001-16671

Dear Mr. Collis :

We have reviewed your filing an d 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 advising us when  you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended September 30, 2012

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
20

Gross Profit , page 22

1. We note your response to comment 1 in our letter dated June 7, 2013.  With a view to
clarifying disclosure in future filings, please quantify for us the fiscal year gross margins
for specialty and non -specialty.  Please also identify any relevant  qualitative factors
considered in concluding that the margins have not historically been significantly
different.

Steven H. Collis
AmerisourceBergen Corporation
June 20 , 2013
Page 2

2. We also note your response to comment 2 in our letter dated June 7, 2013 and your
representation that in future filings you  will clarify what determines whether specialty
sales fall withi n ABSG as opposed to ABDC as well as the relat ive extent to which
ABSG and ABD C report specialty sales.   Please provide us with draft disclosure based
on your response for inclusion in your fu ture periodic reports.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rule s require.   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 provide  a written 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 taki ng 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 federal securities laws of the United States.

Please  contact Adam F. Turk  at (202)  551-3657  or James Lopez at (202) 551 -3536  with
any questions.

Sincerely,

 /s/ James Lopez (for)

John Reynolds
Assistant Director