SecProbe.io

Mail Stop 4561

July 22, 2008

Mr. Harry J. Cynkus Chief Financial Officer Rollins, Inc. 2170 Piedmont Road, N.E. Atlanta, Georgia 30324

Re: Rollins, Inc.
Form 10-K for the year ended December 31, 2007 File No. 001-04422

Dear Mr. Cynkus:

We have reviewed your filing and have the following comment.  Where indicated,
we think you should revise your document in response to this comment.  If you disagree
with a comment, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we  may ask you to provide us with information
so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comment or any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Harry J. Cynkus
Rollins, Inc. July 22, 2008 Page
2

Schedule 14A

Compensation Discussion and Analysis
 Performance-Based Plan, page 18

1. We note your disclosure that bonus amount s are based on specific performance
targets and that in 2007 these targets were met and bonuses paid.  In future filings,
please disclose the actual performance ta rgets, the actual performance results and
an analysis of how this impacted th e actual bonus amounts paid to each named
executive officer.  If you believe some or  all of this disclo sure would cause you
competitive harm, please provide us with  additional information specifically
detailing your competitive harm analysis.  Refer to Instruction 4 to Item 402(b) of
Regulation S-K.  Please a dvise us regarding how you intend to revise this
disclosure in the future.

*   *   *   *
  As appropriate, please respond to this co mment within 10 business days or tell us
when you will provide us with a response.  Please submit a response letter on EDGAR that keys your response to our comment and provides any requested information.
Detailed cover letters greatly facilitate our review.  Please understa nd that we may have
additional comments after reviewin g your response to our comment.
  We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed decision.  Since the company and its management are in
possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.     In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all

Mr. Harry J. Cynkus
Rollins, Inc. July 22, 2008 Page
3
 information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
  Please contact Byron Cooper, Staff Atto rney, at (202) 551-3473 or me at (202)
551-3852 with regard to questions you may have.          S i n c e r e l y ,
   Michael McTiernan  Special Counsel