The Food Marketing Institute (“FMI”) is pleased to respond to the Commission‟s request for comments on its Guides for Advertising Allowances and Other Merchandising Payments and Services, also known as the Fred Meyer Guides (hereafter, “the Guides”). FMI is a not-for-profit organization that conducts programs in public affairs, food safety, research, education and industry relations on behalf of its nearly 1,250 food retail and wholesale member companies in the United States and around the world. FMI‟s U.S. members operate more than 25,000 retail food stores and almost 22,000 pharmacies, with a combined annual sales volume of nearly $650 billion. FMI‟s retail membership is composed of large multi-store chains, regional firms, and independent operators.

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