SecProbe.io

December 23, 2010

Mr. Richard A. Hubbell
President and Chief Executive Officer  RPC, Inc.  2801 Buford Highway, Suite 520  Atlanta, Georgia 30329

Re:  RPC, Inc.
Form 10-K for Fiscal Year Ended December 31, 2009
Filed March 3, 2010
File No. 1-08726

Dear Mr. Hubbell:
We have reviewed your response letter dated September 16, 2010, and we 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 advi sing us when you will provide the requested
response.  If you do not believe our comments apply 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 these comments, we ma y have additional comments.

Form 10-K for Fiscal Year Ended December 31, 2009

 Business, page 2

 1. We note your response to comment two in our  letter dated September 1, 2010.  Please
disclose the information you provided us in your response, regarding the allocation of
liability and related indemnification obligations  set forth in your customer contracts, in
your future filings.  With respect to your  insurance coverage, please disclose the
applicable policy limits and deductibles.  Alternatively, tell us why you believe such
information need not be disclosed.

Mr. Richard A. Hubbell
RPC, Inc.  December 23, 2010 Page 2  Executive Compensation, page 60 (incorporated by  reference to the Definitive Proxy Statement
on Schedule 14A filed on March 24, 2010)
 Compensation Discussion and Analysis, page 14

 2. We note your response to comment eight in  our letter dated September 1, 2010.  In
particular, we note that you provided us with the company’ s definition of the target
corporate performance goal, return on invested  capital, by a letter which was faxed to us
on a supplemental basis.  You did not addr ess why public disclosu re would result in
competitive harm such that the ROIC defi nition could be excluded from your future
filings under Instruction 4 to Item 402(b) of Regulation S-K.  Please disclose the
company’s ROIC definition in future filings, in addition to the related information which
you agreed to disclose.
 3. We note your response to comment nine in  our letter dated September 1, 2010.  Please
provide us with a sample of the disclosure you intend to use, as we  requested in comment
five.  Your sample disclosure should disc uss, for each of the four named executive
officers who received restricted stock aw ards under your Stock Incentive Plan, the
specific aspects of the i ndividual’s performance considered by the compensation
committee in its evaluation and de termination of the award amount.

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.
Please contact Tracey L. McNeil at (202) 551-3392, Alexandra M. Ledbetter at (202)
551-3317, or me at (202) 551-3740 with any questions.
Sincerely,    H. Roger Schwall Assistant Director