SecProbe.io

January 30, 2020
Lazarus Krikorian
Senior Vice President and Chief Accounting Officer
AmerisourceBergen Corporation
1300 Morris Drive
Chesterbrook, PA 19087-5594
Re:Amerisourcebergen Corporation
Form 10-K for Fiscal Year Ended September 30, 2019
Filed November 19, 2019
File No. 001-16671
Dear Mr. Krikorian:
            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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for Fiscal Year Ended September 30, 2019
MD&A
Results of Operations, page 27
1.Please revise to quantify and analyze all material individual factors to which changes in
accounts are attributable.  Consider using tables to list, quantify, and sum these factors and
narrative text to provide analysis of the underlying business reasons for the individual
factors in the tables.  Please also quantify the effects of changes in both price and volume
on revenues and expense categories, where appropriate.
Note 13. Legal Matters and Contingencies
Opioid Lawsuits and Investigations, page 73
2.We note you recorded a charge of $66.7 million in the fourth quarter of the fiscal year
ended September 30, 2019 related to an agreement in principle with two Ohio counties
related to opioids.  Please tell us the amount of your settlement and what amount, if any,

 FirstName LastNameLazarus Krikorian
 Comapany NameAmerisourceBergen Corporation
 January 30, 2020 Page 2
 FirstName LastName
Lazarus Krikorian
AmerisourceBergen Corporation
January 30, 2020
Page 2
was previously accrued.
3.With regard to the Multidistrict Litigation (“MDL”), we note from your filing that you are
engaged in negotiations with plaintiffs’ representatives regarding a potential settlement
framework.  Please tell us whether you have made an offer to settle and whether there is
an amount for which you would be willing to settle these matters.
4.You state on page 75 that you are unable to estimate the range of possible loss because
you are not in a position to assess the likely outcome.  Please tell us what the term
outcome refers to (e.g., settlement vs. trial, or result of settlement or trial).  Because the
matter is disclosed, we assume you believe there is at least a reasonable possibility of a
material adverse outcome, either from settlement or trials.  Therefore, please tell us why
an estimate of the range of reasonably possible loss is dependent on determining the
outcome.  In this regard, we believe an estimate of a range of loss could contemplate
different potential outcomes.
Notes to Consolidated Financial Statements
Note 15. Business Segment Information, page 77
5.Please tell us whether the first table in this note is intended to provide disclosure of
revenue on a disaggregated basis under ASC 606.  If so, please revise to so indicate.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Aamira Chaudhry at 202-551-3389 or Lyn Shenk at 202-551-3380 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services