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    rpcrespltr80108.htm

    RPC
Incorporated, 2170 Piedmont Road NE., Atlanta,
GA  30324    Telephone:  (404)
321-2140    Facsimile:  (404)
321-5483

    VIA
EDGAR

    August 4,
2008

    Mr. Brad
Skinner

    Senior
Assistant Chief Accountant

    Division
of Corporation Finance

    United
States Securities and Exchange Commission

    100 F
Street, N.E.

    Washington,
DC 20549-7010

              RE:

              RPC,
      Inc.

              Form
      10-K for the Fiscal Year ended December 31, 2007

              Filed
      March 4, 2008

              Form
      10-Q for the Quarterly Period ended March 31, 2008

              Filed
      May 1, 2008

              File
      No. 001-08726

              Your
      comment letter dated July 22, 2008

    Dear Mr.
Skinner:

    Below is
our response to your comment raised in the above referenced letter.

    Form 10-K for the fiscal
year ended December 31, 2007

    Note 1. Significant
Accounting Policies

    Revenue, page
38

              1.

              We
      note disclosure indicating that your revenues are generated from services,
      equipment rentals and product sales.  We also note Revenues and
      Costs of services rendered and good sold are presented as single line
      items on your Consolidated Statement of Operations.  Tell us how
      you considered Rule 5-03 of Regulation S-X and how you concluded the
      current presentation on your Consolidated Statement of Operations is
      appropriate.

    RESPONSE

    We
primarily provide services and equipment to customers for various oilfield
related applications.

    Equipment
rental is a standard oilfield industry term and is highly service intensive and
for a short duration.  Equipment rental is comprised of the
following:

              ·

              equipment
      that we own and that we use as required to perform our services directly
      to a customer’s oil and gas well.  We bill the customer for the
      equipment usage required to perform our
service.

             Page
    2

               August 4,
      2008

              ·

              equipment
      that we own and make available for a customer’s use based on the
      customer’s needs.  This is a specialized equipment rental
      service that requires adherence to rigorous industry specific and customer
      standards related to the equipment including inspection, cleaning,
      preparing, transporting and maintenance. The industry standards are
      promulgated by the American Petroleum Institute and the customer standards
      vary based on their job specifications.  In addition, we provide
      customers with engineering consultation services related to the equipment
      regarding appropriate pressure rating, length, diameter, capacity and
      other critical configurations to meet their operational
      requirements.  Sometimes we obtain equipment from third parties
      to supplement customer needs and service requirements to complete the
      array of equipment needed on the particular job.  We provide
      this service to our customers allowing them to reliably use a variety of
      specialized equipment that are compliant and enable them to safely and
      effectively drill, complete and maintain their oil and gas
      wells.

    The
Company generates a minimal amount of revenue from product sales that are
assembled and sold to customers.   Revenues from these product
sales have always been less than 10 percent of our consolidated revenues and
have been steadily declining in recent years, primarily because of the high
growth rates in our service business.  Therefore we have concluded
that the current presentation of a single “Revenues” line in our Consolidated
Statement of Operations is appropriate and consistent with current industry
practices.

    In future
filings beginning with the quarterly report for the third quarter of 2008, we
will make the following changes.   We will alter the consolidated
Statements of Operations as follows:

              ·

              “Cost of services rendered and
      goods  sold” to “Cost of
      revenues”

    We will
also modify the disclosure on our revenue recognition policy footnote to read as
follows:

    “Revenues

    RPC’s
revenues are generated principally from providing services and the related
equipment.  Revenues are recognized when the services are rendered and
collectibility is reasonably assured.  Revenues from services and
equipment are based on fixed or determinable priced purchase orders or contracts
with the customer and do not include the right of return.  Rates for
services and equipment are priced on a per day, per unit of measure, per man
hour or similar basis.  Sales tax charged to customers is presented on
a net basis within the consolidated statement of operations and excluded from
revenues.”

    The
Company acknowledges the following:

              ·

              the
      company is responsible for the adequacy and accuracy of the disclosure 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 federal securities
      laws of the United States.

    I trust
that we have responded in sufficient detail to all of your
comments.  Please do not hesitate to contact me at (404) 321 2149 if
you need further information.

    Sincerely,

    /s/ Ben M. Palmer

    Ben M.
Palmer

    Vice
President and Chief Financial Officer

    cc:   Mr.
Bob Carroll