SecProbe.io

April 1, 2015

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, 2014
Filed February 25, 2015
File No. 1 -04422

Dear Mr. Cynkus :

We have limited our review  of your filing  to the financial statements and related
disclosures 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respon d.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.

Item 8. Financial Statements and Supplementary Data

Note 1 – Summary of Significant Accounting Policies, page 31

1. We note your disclosure on page 34 that all share and per share data appearing in the
consolidated financial statements are pres ented prior to your three -for-two stock split and
further note your disclosure in Note 19 on page 54.  Please describe the consideration you
gave to the presentation requirements included in ASC 505 -10-S99-4.

We urge all persons who are responsible for the ac curacy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all fac ts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mr. Harry J. Cynkus
Rollins, Inc.
April 1, 2015
Page 2

  In responding to our comments, please provide  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 as sert 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 Isaac Esquivel, Staff Accountant,  at (202) 551 -3395 or me at
(202) 551 -3446 with any ques tions.

Sincerely,

 /s/ Jaime G. John

Jaime G. John
Branch Chief