SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

June 12 , 2013

Via E -mail
Mr. Harry J. Cynkus
Chief Financial  Officer
Rollins, Inc.
2170 Piedmont Road, N.E.
Atlanta, GA 30324

 RE: Rollins, Inc.
Form 10 -K for the Fiscal Year Ended December 31, 20 12
  Filed February 27, 2013
  File No. 1-04422

Dear Mr. Cynkus :

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why  in your response.

After reviewing any amendment to your filing and the  information  you provide in
response to these comments, we may have  additional comments.

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Revenues, page 22
1. We note that revenues have increased steadily over the past five years.  Your disclosure
indicates that this is due to a combination of increased sale s/closings and increased
prices.  In future filings, please clarify the amount of increase that is due to increased
sales, the amount due to pricing increases, and the amount due to other factors.
2. We note that you generate revenues from commercial pest con trol, residential pest
control and the Company’s termite business.  Please tell us how you have determined that
the Company operates in one operating segment.  For reference see ASC 250 -10-50.

Mr. Harry J. Cynkus
Rollins, Inc.
June 12, 2013
Page 2

 Liquidity and Capital Resources, page 24
3. Tell us your consider ation of providing liquidity disclosures to discuss the potential tax
impact associated with the repatriation of undistributed earnings of foreign subsidiaries.
We note that currently you have over $40 million in cash held in foreign banks.  In this
regard , please consider disclosing the impact of repatriating the undistributed earnings of
foreign subsidiaries. In addition if you do not plan to repatriate the funds please disclose
this in future filings.  We refer you to Item 303(a)(1) of Regulation S -K and  Section IV of
SEC Release 33 -8350.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing inclu des the  information the Securities Exchange Act of
1934 and all applicable Exchan ge Act rules require.  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 responding to our commen ts, please p rovide a written  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 comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact William Dem arest, Staff Accountant, at (202) 551 -3432 or me at (202)
551-3486 with any questions .

        Sincerely,

        /s/ Daniel L. Gordon

        Daniel L. Gordon
        Branch Chief