SecProbe.io

December 6, 2011
 Via E-mail

Ben M. Palmer, Vice President and CFO RPC, Inc. 2801 Buford Highway Suite 520 Atlanta, Georgia 30329
Re: RPC, Inc.
 Form 10-K for Fiscal Year Ended
December 31, 2010 Filed March 4, 2011 File No. 1-08726

Dear Mr. Palmer:
 We have reviewed your filing 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 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, 2010

 Exhibit 31 – Section 302 Certifications

 1. We note that the Section 302 certifications fi led with your Form 10-K are dated March 4,
2010.  Please revise to provide currently dated Section 302 certifications.  Refer to Rule
13a-14 or Rule 15d-14(a) of the Exchange Act.
 Exhibit 32 – Section 906 Certifications

 2. We note that the certifications furnished pur suant to Section 906 of  the Sarbanes-Oxley
Act make reference to your Form 10-K for the period ended December 31, 2009 (i.e.,
rather than the period ended December 31, 2010).  In addition, the signatures provided by

Ben M. Palmer
RPC, Inc. December 6, 2011 Page 2

 your officers are dated March 4, 2010.  Please f ile a full amendment to your Form 10-K
to address the deficiencies in these certifications.  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:
 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.

You may contact Sandy Eisen at  (202) 551-3864 or me at (202) 551-3311 if you have any
questions.
Sincerely,

 /s/ Ethan Horowitz

Ethan Horowitz Branch Chief