October 2, 2014
VIA EDGAR
Division of Corporation Finance
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Attn: | Mr. Jim B. Rosenberg, Senior Assistant Chief Accountant |
| Ms. Lisa Vanjoske, Assistant Chief Accountant | |
| Mr. Frank Wyman, Staff Accountant | |
| RE: | Express Scripts Holding Company |
| Form 10-K for the Fiscal Year Ended December 31, 2013 | |
| Filed February 20, 2014 | |
| File No. 001-35490 | |
Ladies and Gentlemen:
Express Scripts Holding Company (“the Company”) has received the comment letter from the Staff of the Securities and Exchange Commission (“the Staff”) dated September 22, 2014 (the “Comment Letter”) related to the above referenced filing.
We have commenced work on a letter in response to the Staff’s comments. However, the Company requires additional time to respond fully to the Staff’s comments.
Accordingly, we respectfully request an extension of the time to respond to the Comment Letter. We anticipate filing our response on or before October 20, 2014.
We are grateful for the Staff’s assistance in the matter. Please do not hesitate to contact me at (314) 684-6721 with any questions you may have regarding this request.
Sincerely,
Express Scripts Holding Company
/s/ Christopher K. Knibb_____________________
Christopher K. Knibb
Vice President and Chief Accounting Officer
| cc: | George Paz, Chairman and Chief Executive Officer |
| Cathy R. Smith, Executive Vice President and Chief Financial Officer | |