The Food Marketing Institute (FMI) is writing in opposition to the proposed merger of Express Scripts (ESI) and Medco Health Solutions (Medco), two of the top three leading pharmacy benefit managers (PBMs). If this merger is approved, the new PBM would wield exorbitant market power, producing anticompetitive effects on pharmacy patient care and health care costs to both consumers and to FMI members as employers. FMI respectfully requests that that the FTC closely and carefully analyze the proposed consolidation.

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