CONCENTRATE IN OUR BEST IDEAS

FOCUS ON HIGH-QUALITY COMPANIES

INSIST ON A MARGIN OF SAFETY

INVEST IN BUSINESSES WE UNDERSTAND

INVEST FOR THE LONG-TERM

EAT OUR OWN COOKING

COMMENTARY

Performance Disclosures

Focused Investors LLC ("FI") seeks to achieve long-term capital appreciation through a concentrated value-oriented investment strategy. FI's concentrated value strategy invests client assets primarily in common stocks of companies that are trading at prices significantly below FI's estimate of their intrinsic values at the time of initial purchase. FI believes that it generally takes several years for the gap between the price of an undervalued security and FI's estimate of its intrinsic value to close, if at all. In this regard, FI's concentrated value strategy is best suited for investors with a long-term investment horizon (i.e., no less than five years).

Because FI's portfolios are relatively concentrated, the performance of each holding will have a greater impact on an account's total return and may make the return more volatile than a more diversified portfolio. As with any investment vehicle, there is always the potential for gain as well as the possibility of loss.

Returns for the Russell 1000 Value® Index are provided to represent the investment environment existing during the periods shown. For comparison purposes, index returns do not reflect transaction costs, management fees, or other expenses that would be incurred in managing an account. While FI's objective is to outperform its benchmark, this does not imply that FI's portfolio strategy will share or track the same or similar characteristics as the benchmark. In addition, there is no guarantee that FI will achieve its objective.

Forward-Looking Statements

As investment managers, one of our responsibilities is to communicate with our investors in an open and direct manner. In so far as some of our opinions and comments in our letters are based on current management expectations, they are considered "forward-looking statements" which may or may not be accurate over the long term. While we believe we have a reasonable basis for our comments and we have confidence in our opinions, actual results may differ materially from those we anticipate. You can identify forward-looking statements by words such as "believe," "expect," "may," "anticipate," and other similar expressions when discussing prospects for particular portfolio holdings and/or the markets, generally. We cannot, however, assure future results and disclaim any obligation to update or alter any forward-looking statements, whether as a result of new information, future events, or otherwise. Further, information provided in this letter should not be considered a recommendation to purchase or sell any particular security.

Form ADV

Our most recent Form ADV (Parts I and II) is available at http://www.adviserinfo.sec.gov.






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