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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

Date
March 7, 2011
Author
Pamela Howell
Form
UPLOAD
Company
CINTAS CORP (CTAS) (CIK 0000723254)

Letter

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

Show Raw Text
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