SEC Comment Letter for ROLLINS INC (ROL) (CIK 0000084839) (ROL) — Jan 31, 2011
ROLLINS INC (ROL) (CIK 0000084839)
Date: Jan. 31, 2011 · CIK: 0000084839 · Accession: 0000000000-11-006150
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File numbers found in text: 001-04422
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
January 31, 2011
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, 2009 Proxy Statement on Schedule 14A, filed March 16, 2010 File No. 001-04422
Dear Mr. Cynkus:
We have reviewed your response letter date d December 7, 2010 and have the following
additional comment.
Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.
After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments. Form 10-K for the Fiscal Year Ended December 31, 2009
1. We have reviewed your response to comment 1 and your suggested disclosure for future
filings. In addition to provi ding this disclosure within Management’s Discussion and
Analysis of Financial Condition please include this disclosure within the footnotes to the
financial statements.
You may contact William Demarest, Staff Acco untant, at (202) 551-3432 or me at (202)
551-3486 with any questions regarding comments on the financial statements and related
matters. Please contact Adam Turk, Staff Atto rney at (202) 551-3657 with any other questions.
S i n c e r e l y , Daniel L. Gordon B r a n c h C h i e f