SEC Comment Letter for CINTAS CORP (CTAS) (CIK 0000723254) (CTAS) — Mar 7, 2011
CINTAS CORP (CTAS) (CIK 0000723254)
Date: March 7, 2011 · CIK: 0000723254 · Accession: 0000000000-11-014278
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File numbers found in text: 000-11399
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March 7, 2011
Scott D. Farmer Chief Executive Officer Cintas Corporation 6800 Cintas Boulevard P.O. Box 625737 Cincinnati, OH 45262-5737
Re: Cintas Corporation
Form 10-K for the fiscal year ended May 31, 2010
Filed July 30, 2010 File No. 000-11399
Dear Mr. Farmer:
We have reviewed your filing and have th e following comment. 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 advi sing us when you will provide the requested
response. If you do not believe our comment applies to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
After reviewing any amendment to your filing and the information you provide in
response to this comment, we may have additional comments.
Item 9.01. Financial Statements and Exhibits
We note that you have not included all of the exhibits and/or schedul es to Exhibits 10.1,
10.3 and 10.5. Please confirm that you will file a complete copy of these exhibits with
your next Exchange Act periodic report. We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e. 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 comments, please provi de a written statement from the company
acknowledging that:
Scott D. Farmer Cintas Corporation March 7, 2011 Page 2
• the company is responsible for the adequacy an d accuracy of the disclo sure 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 federa l securities laws of the United States.
Please contact Damon Colbert at (202) 551 3581 or Pamela Howell at (202) 551 3357
with any questions.
Sincerely,
/s/ Pamela Howell for John Reynolds
Assistant Director