TEXT-EXTRACT 2 filename2.txt November 27, 2018 Robert S. Snead Interim Chief Financial Officer Owens & Minor, Inc. 9120 Lockwood Boulevard Mechanicsville, VA 23116 Re: Owens & Minor, Inc. Form 10-K for the Year Ended December 31, 2017 Filed February 23, 2018 File No. 001-09810 Dear Mr. Snead: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, 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 providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment apply to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the Year Ended December 31, 2017 Management's Discussion and Analysis of Financial Condition and Results of Operations Financial Highlights Use of Non-GAAP Measures, page 18 1. We note your computations of non-GAAP measures Adjusted Operating Earnings, Adjusted Net Income and Adjusted EPS exclude acquisition related intangible assets amortization. Please tell us how you determined the adjustments to exclude the amortization of certain acquired intangible assets do not substitute individually-tailored income or expense recognition methods for those of GAAP. Refer to Question 100.04 of the Non-GAAP Financial Measures Compliance and Disclosure Interpretations. Robert S. Snead Owens & Minor, Inc. November 27, 2018 Page 2 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 Joanna Lam at 202-551-3476 or Raj Rajan at 202-551-3388 with any questions. Sincerely, FirstName LastNameRobert S. Snead Division of Corporation Finance Comapany NameOwens & Minor, Inc. Office of Beverages, Apparel and November 27, 2018 Page 2 Mining FirstName LastName