SecProbe.io

Mail Stop 4628

February 3 , 201 7

Via E -mail
Ben M. Palmer
Chief Financial Officer
RPC, Inc.
2801 Buford Highway, Suite 520
Atlanta, Georgia 30329

Re: RPC, Inc.
Form 10 -K for Fiscal Year Ended  December 31, 201 5
Filed February 2 9, 201 6
Supplemental Response dated January 12, 2017
File No. 1 -08726

Dear Mr. Palmer :

We have reviewed  your January 12, 201 7 response to our comment letter 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respon d.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have additional comments.
Unless we note otherwise, our references to prior comme nts are to comments in our December
15, 2016 letter .

Form 10 -K for Fiscal Year Ended December 31, 2015

Financial Statements and Supplementary Data, page 33

Notes to Consolidated Financial Statements, page 38

Note 12: Business Segment Information, page 57

1. We note your response to prior comment 1  which states that you have two operating
segments .  Please address the following in order to further clarify your response:

Ben M. Palmer
RPC, Inc.
February 3, 2017
Page 2

  Address whether you have established a segment manager for each of the operating
segments.  As part of your response, include information further describing the
responsibilities of both general managers and service line managers;

 Identify individuals other than the general managers who report directly to the chief
operat ing decision maker (“ CODM”) and describe their roles;

 Tell us more about the reporting package reviewed by the CODM on a monthly basis,
including the nature of service line level financial information included in the
reporting package.  Also tell us wheth er your board of directors reviews similar
information;

 Explain your annual budgeting process in greater detail.  Your response should
describe how budgets are prepared, who approves the budget at each step of the
process, the level of detail discussed at  each step, and the level at which the CODM
makes changes to the budget;

 Describe the level of detail communicated to the CODM when actual results differ
from budgets and who is involved in meetings with the CODM to discuss budget -to-
actual variances;

 Explain the degree to which the CODM relies on input from general managers and
service line managers in making decisions with regard to operations and resource
allocation.  In addition, tell us how often your CODM meets with these individuals
and describe topics typically discussed at these meetings;

 Clarify the process through which resources are allocated to individual service lines,
including the manner in which the services offered in each operating segment are
considered; and,

 Describe the basis for determining the compensation  of the individuals that report to
the CODM.

 Refer to FASB ASC 280 -10-50-1, 50 -6, and 50 -7.

Ben M. Palmer
RPC, Inc.
February 3, 2017
Page 3

 You may contact Wei Lu, Staff Accountant, at (202) 551 -3725 or me at (202) 551 -3311
with any questions.

Sincerely,

 /s/ Ethan Horowitz

Ethan Horowitz
Accounting Branch Chief
Office of Natural Resources