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     SEC Comment Response Letter

May 17, 2006

United States Securities
and

Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington, DC 20549

Attention:    Michael Moran,
Branch Chief

Re:
Cintas
Corporation

Form
10-K for Fiscal Year Ended May 31, 2005

Filed August 15, 2005

File No. 0-11399

Ladies and Gentlemen:

This letter sets forth below the
detailed responses of Cintas Corporation (the “Company”) to the comments of the
Staff of the Commission in its letter to the Company dated April 17, 2006, with respect to
the above referenced Form 10-K filing of the Company. In responding to the Staff’s
comments, we have utilized the headings and numbering system in the Staff’s letter.
This letter has been filed with the Commission as correspondence through EDGAR.

FORM 10-K FOR THE YEAR
ENDED MAY 31, 2005

Notes to Consolidated
Financial Statements, page 30
13.  Segment Information, page 41

SEC Comment #1

We note your response to comment 4 in
our letter dated February 21, 2006. Please tell us each of the operating segments
identified in accordance with paragraphs 10 through 15 of SFAS No. 131. Explain why the
identified operating segments share both similar economic characteristics and a majority
of the aggregation criteria and why aggregation into two reportable segments is permitted.
See paragraph 4 of EITF 04-10. Please support your explanation with quantitative support
for each operating segment to substantiate your conclusions. The provided information
should include historical sales, margin and operating profit figures for the recent five
year period.

Response

Cintas’ products and services
are designed to enhance our customers’ images and brand identification as well as
provide a safe and efficient work place. Our products are sold through two business
models: a contractual, regular recurring rental business with a significant service
component and a direct sale, order fulfillment, distribution business. The use of each
model is determined by customers’ decisions to rent or buy, with many customers
requiring elements of both. These two business models provide the basis for our two
reportable operating segments: Rentals and Other Services.

Our Rentals reportable operating
segment is predominantly the rental and delivery of uniforms, mats, mops, towels, restroom
and hygiene services, cleanroom garments and flame resistant clothing to our customers.
These products and services are provided to our customers on a contractual basis and are
delivered through our Rentals route distribution network, typically on a weekly basis.

The Other Services reportable
operating segment consists primarily of the direct sale of garments, first aid products,
fire protection products, safety products and branded promotional products. Unlike the
Rentals operating segment, there are few service agreements with these customers. The
business model in this reporting segment is a direct sale, order fulfillment, distribution
business, where the fundamental focus is on the sourcing, the warehousing and the
distribution of products. While our product offering within this reporting segment may
change from time to time (i.e., addition of new safety products, replacement of garment
styles, etc.), the nature of the products do not change. That is, the products selected
continue to promote image and safety in the workplace. In addition, the business model and
the production process do not change with any differentiation in product offerings. We
focus on the fundamentals of sourcing, warehousing and distribution, regardless of the
product offering.

The following is our evaluation for
defining our reportable operating segments in accordance with SFAS No. 131 (SFAS 131),
Disclosures about Segments of an Enterprise and Related Information.

We have eight business units which
supply image and safety products and services to our customer base. They are as follows:

•
Rentals

•
Uniform
Sales

•
First
Aid & Safety Sales

•
Catalog
Sales

•
Fire
Protection Sales

•
Sourcing
and Distribution

•
Document
Management Sales

•
Government
Sales

Determination of
Operating Segments

SFAS 131 defines operating segments
in paragraphs 10 through 15. SFAS 131 paragraph 10 defines an operating segment as a
component of an enterprise that a.) engages in business activities from which it may earn
revenues and incur expenses, b.) whose operating results are regularly reviewed by the
enterprise’s chief operating decision maker (“CODM”) to make decisions
about resources to be allocated to the segment and assess its performances and c.) for
which discrete financial information is available.

The following reflects our
assessments of each business unit with respect to paragraph 10. A “Yes” denotes
that the particular business unit meets the referenced criteria.

     Business Unit
     Criteria A

Earn Revenue,

Incur Expenses
     Criteria B

Oper. Results Regularly

Reviewed by CODM
     Criteria C

Discrete Financial

Information Available

     Rentals
     Yes
     Yes
     Yes

     Uniform Sales
     Yes
     Yes
     Yes

     First Aid & Safety Sales
     Yes
     Yes
     Yes

     Catalog Sales
     Yes
     Yes
     Yes

     Fire Protection Sales
     Yes
     Yes
     Yes

     Sourcing and Distribution
     No
See Note 1
     Yes
See Note 1
     Yes

     Document Management Sales
     Yes
     Yes
     Yes

     Government Sales
     Yes
     Yes
     Yes

Note 1 – Sourcing and
Distribution does not earn revenue. Its primary function is to source and distribute
product to the Uniform, First Aid & Safety, Catalog and Fire Protection sales business
units. The operating results regularly reviewed by the chief operating decision maker for
Sourcing and Distribution relate to operational measurements such as cost per unit.

SFAS 131 paragraph 11 indicates that
not every part of an enterprise is necessarily an operation segment or part of an
operating segment. Our corporate financing (i.e., interest income and interest expense) is
not considered to be an operating segment. As such, it is reported as
“Corporate” in our segment reporting disclosure.

SFAS 131 paragraphs 12 and 14 define
the terms CODM and segment manager. In accordance with those definitions, we note the
following as CODM(s) and Segment Manager(s) for each business unit.

     Business Unit
     CODM(s)
     Segment Manager

     Rentals
     Scott D. Farmer, CEO
 and
     John W. Milligan,

     John W. Milligan,
     President & COO, Rental Division
and

     President & COO, Rental Division
     14 Vice Presidents

     Uniform Sales
     Scott D. Farmer, CEO
     William L. Cronin,

     President & COO, National Account

     Division

     First Aid & Safety Sales
     Scott D. Farmer, CEO
     David Pollak, Jr.,

     President & COO, First Aid & Safety

     Division

     Catalog Sales
     Scott D. Farmer, CEO
     William W. Goetz,

     Vice President, Marketing &

     Merchandising

     Fire Protection Sales
     Scott D. Farmer, CEO
     David Pollak, Jr.,

     President & COO, First Aid & Safety

     Division

     Sourcing and Distribution
     Scott D. Farmer, CEO
     Kevin M. Bien,

     and
     Vice President, Global Sourcing

     J. Phillip Holloman,
     and

     Sr. Vice President, Global Supply
     Laura J. Hendricks,

     Chain Management
     Vice President, Distribution &

     and Six Sigma
     Production Planning

     Document Management Sales
     Scott D. Farmer, CEO
     Todd M. Schneider,

     Vice President, Document Management

     Division

     Government Sales
     Scott D. Farmer, CEO
     David Warns,

     and
     Director of Government Operations

     William L. Cronin, President & COO,

     National Account Division

Scott D. Farmer, CEO, is the CODM for
all Cintas business units. Several business units have an additional CODM due to size of
operations, span of control, or business unit complexities or uniqueness.

SFAS 131 paragraph 13 discusses
situations where the three characteristics of operating segments, as described in
paragraph 10, do not clearly identify a single set of operating segments. In Cintas’
case, however, the three characteristics of operating segments described in paragraph 10
do clearly identify a single set of operating segments. As such, we do not evaluate
additional factors.

SFAS 131 paragraph 15 describes
situations involving matrix forms of organizations. This paragraph does not apply, since
Cintas did not have a matrix form of organization.

Based on our evaluation of the Cintas
business units with respect to SFAS 131 paragraphs 10 through 15, we conclude that we have
seven operating segments. They are as follows.

•
Rentals

•
Uniform
Sales

•
First
Aid & Safety Sales

•
Catalog
Sales

•
Fire
Protection Sales

•
Document
Management Sales

•
Government
Sales

Determination of
Reportable Operating Segments

In determining the reportable
operating segments, which are required to be reported in the footnotes to our financial
statements, we perform the following steps.

               1.

               We determine which operating segments meet the quantitative thresholds as
               described in paragraph 18 of SFAS 131 (i.e., the 10% tests). Operating segments,
               or the aggregation of operating segments, that meet the quantitative thresholds
               are reportable.

               2.

               We determine which operating segments meet the aggregation criteria as described
               in paragraph 17 of SFAS 131 and EITF 04-10. The operating segments that meet the
               aggregation criteria can be aggregated for purposes of determining whether the
               aggregated segments meet the quantitative thresholds. Operating segments, or the
               aggregation of operating segments, that meet the quantitative thresholds are
               reportable.

               3.

               We test whether the reportable segments contribute at least 75% of total
               consolidated revenue. If they do not, additional operating segments that do not
               individually meet the quantitative thresholds must be reported to reach the 75%
               of consolidated revenue.

               4.

               We evaluate the need for an “All Other” category, grouping operating segments that are not
               individually reportable and that do not share a majority of the aggregation
               criteria with another operating segment.

The Rentals operating segment meets
the quantitative criteria described in step #1 above and is therefore an individually
reported operating segment. Quantitative financial information for the Rentals operating
segment, including historical sales, margin and profit figures for the last five year
period, is included as Exhibit I to this letter.

The Uniform Sales operating segment,
the First Aid and Safety Sales operating segment, the Catalog Sales operating segment and
the Fire Protection Sales operating segment each do not meet the quantitative levels
described in #1 above (i.e., they do not meet the 10% tests). Quantitative financial
information for each of these operating segments, including historical sales, margin and
profit figures for the last five year period, is included as Exhibit II to this letter.

These four operating segments combine
to form our direct sale, order fulfillment, distribution business (the “direct sale
operating segments”) and follow the same business model. Sourcing and Distribution is
an integral part of this model. As such, we have included its financial

information on Exhibit II with that
of the four direct sale operating segments. The direct sale operating segments share
economic characteristics and the aggregation criteria and are therefore aggregated into
one reportable operating segment (Other Services) as provided for in paragraph 17 of SFAS
131. An analysis of the similarity of economic characteristics and the aggregation
criteria of paragraph 17 follows:

Economic Characteristics

Evidence of similar economic
characteristics for these operating segments is provided on Exhibit II. With two
exceptions, for each of the five years presented, gross margins fall within a 5% range and
selling and administrative expenses fall within a 4% range. The only exceptions are in
FY2002, when our entire business was dramatically affected by the terrorist events of
9/11, and in fire protection for FY2003, as we first introduced fire protection products
at the end of that fiscal year. In addition to sharing economic characteristics, the
products and services provided within the Other Services reportable operating segment
share the aggregation criteria described in SFAS 131 paragraphs 17 (a-e) as outlined
below:

a.    Nature of Products and
Services

The nature of products and services
in each of the direct sale operating segments is similar. The products provided are all
designed to meet our strategic goal of both enhancing our customers’ image and safety
in the workplace. Certainly, the individual products in these operating segments have
different physical characteristics (i.e., garments, mats, first aid supplies, fire
extinguishers, etc.). However, the nature and focus of the products remains the same: they
are products sold to and used by business customers to enhance their image and brand
identity and to improve safety and efficiency at their facilities.

b.    Nature of Production
Processes

The nature of the production processes
within these operating segments is similar, consisting of the design, identification and
sourcing of high quality products.

Once we identify products and product
specifications are determined, our centralized supply chain department makes sourcing
decisions (i.e., make or buy) based primarily on required volume levels, timeliness of
deliveries, branding requirements and exclusive design needs. These decisions lead to
supplier selection. Our supply chain department then manages supplier relationships to
ensure that specifications are met, price points remain competitive and quality production
continues. The nature of this production process remains consistent regardless of our
direct sale product offering.

c.    Type or Class of
Customer

The type or class of customer being
serviced by the products in the direct sale operating segments is a broad class of
customer in line with our goal of enhancing our customers’ images and brand
identification as well as providing them a safe and efficient work place. We view every
business in the United States and Canada as a potential customer for each direct sale
operating segment and indeed have customers in most SIC codes in this segment (as well as
in our Rentals segment). Our marketing data indicates that our direct sale operating
segments share 17 of the top 20 SIC codes, demonstrating not only the diversity of our
customer base but also the similar nature of our customers in each of the direct sale
operating segments.

d.    Methods and
Distribution

The methods of distribution within
these direct sale operating segments are similar. Our distribution function consists of
warehousing these products primarily through our distribution network, managing inventory
levels and then delivering these products to our customers’ place of business in the
most cost efficient manner, including direct delivery through a local representative
and/or a local delivery route.

e.    Nature of Regulatory
Environment

While we sell products and provide
services to many regulated industries, our business of providing the products in each of
the direct sale operating segments is not considered heavily regulated.

A summary of the aggregation criteria
follows.

     Uniform

Sales
     First Aid & Safety

Sales
     Catalog

Sales
     Fire Protection

Sales

     Nature of Product
     Sale of Uniform and
     Sale of First Aid and
     Sale of Uniform and