SEC Comment Letter for RPC INC (RES) (CIK 0000742278) (RES) — Apr 23, 2013

RPC INC (RES) (CIK 0000742278)
Date: April 23, 2013 · CIK: 0000742278 · Accession: 0000000000-13-021933

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AI Filing Summary & Sentiment

Date

December 31, 2011

Author

/s/ A.N. Parker for

Form

UPLOAD

Company

RPC INC (RES) (CIK 0000742278)

Letter

April 23 , 2013 Via E -mail 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 the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 File No. 1-8726

Dear Mr. Hubbell:

We have completed our review of your filing. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with resp ect to the company or 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 federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Please contact Kevin Doughe rty at (202) 551 -3271 or in his absence, Timothy S. Levenberg at (202) 551 -3707 with any questions.

Sincerely,
/s/ A.N. Parker for

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April 23 , 2013

Via E -mail
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 the Fiscal Year Ended December 31, 2011
Filed February 29, 2012
  File No.  1-8726

Dear Mr.  Hubbell:

We have completed our review of your filing.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with resp ect to the company or 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
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing includes the
information the Securities Exchange Act of 1934 and all applicable rules require.

Please contact Kevin Doughe rty at (202) 551 -3271 or in his absence, Timothy S.
Levenberg  at (202) 551 -3707  with any questions.

        Sincerely,

/s/ A.N. Parker for

        H. Roger Schwall
        Assistant Director

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