ROLRollins, Inc.

Please disclose how you expect COVID-19 (and the resulting increase in people working from or confined to their homes) to impact your future operating results, including whether you expect that COVID-19 will impact future operations differently than how it affected the current period.

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If possible, please also disclose the extent to which you believe revenue gains are attributable to COVID-19, pricing changes, or general growth in the market for your services.

At this time, we are unable to predict the extent to which the COVID-19 pandemic will ultimately impact our future operating results, including whether we expect the COVID-19 pandemic to impact future operations differently than how it affected operations during the quarterly period ended September 30, 2021.

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Our understanding of such impact will likely depend on future developments, which are highly uncertain and cannot be predicted at this time, including, but not limited to, the continuing duration and spread of the outbreak (and current and future variants thereof), its severity (and the severity of such current and future variants), current and future actions to contain and mitigate the virus or treat its impact (including the continuation of work from home arrangements and stay at home orders), and how quickly and to what extent normal economic and operating conditions can resume, given these uncertainties.

Additionally, we are unable to quantify the extent to which we believe revenue gains are attributable to COVID-19 versus pricing changes or general growth in the market for our services with a sufficient level of precision as required for disclosure. However, in future periods, to the extent such information is ascertainable, we will take in account the Staff’s comment when preparing our financial reports on Forms 10-K and 10-Q.

If any member of the Staff has any questions or additional comments, please contact our counsel, Stephen Fox at (404) 873-8528 or Leah Braukman at (404) 873-8144 of Arnall Golden Gregory LLP.

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We note your disclosure of the valuation approach and inputs used to value the Level 2 and 3 assets of your defined benefit pension plan. Please expand your disclosure in future filings to include a description of the valuation techniques used in accordance with ASC 820-10-50-2bbb.

Atlanta ● Washington D.C. Read in the reply ↗

We note your disclosure on page 34 that all share and per share data appearing in the consolidated financial statements are presented prior to your three-for-two stock split and further note your disclosure in Note 19 on page 54. Please describe the consideration you gave to the presentation requirements included in ASC 505-10-S99-4.

Such changes in the capital structure must be given retroactive effect in the balance sheet. An appropriately cross-referenced note should disclose the retroactive treatment, explain the change made and state the date the change became effective.

The Company’s stock split was paid on March 10, 2015 by the issuance on March 10, 2015 of one additional common share for each two common shares held of record at February 10, 2015. The Company’s Form 10-K for the year ended December 31, 2014 and the related release of its financial statements for that year occurred on February 25, 2015.

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Accordingly, the effective date of the stock split was after the date of the release of the Company’s financial statements rather that before such date as referenced in ASC 505-10-S99-4. The Company will give retroactive effect to the stock split consistent with the referenced accounting literature in the Company’s future filings and financial statements.

The Company has authorized us to advise you that the Company acknowledges that:

· 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.

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We note that revenues have increased steadily over the past five years. Your disclosure indicates that this is due to a combination of increased sales/closings and increased prices. In future filings, please clarify the amount of increase that is due to increased sales, the amount due to pricing increases, and the amount due to other factors.

When referring to causes of increased/decreased revenues, the Company will clarify the amount of the increase/decrease to revenue beginning with its Form 10-Q for the period ending June 30, 2013. Read in the reply ↗

We note that you generate revenues from commercial pest control, residential pest control and the Company’s termite business. Please tell us how you have determined that the Company operates in one operating segment. For reference see ASC 250-10-50.

Atlanta · Miami · Washington D.C.

In accordance with ASC 280-10-50-1, the Company determined that the commercial, residential and termite service lines are not operating segments. These service lines do have determinable revenues, but their expenses, balance sheet and cash flows are comingled and cannot be used to assess any individual service line’s performance. The Company does not prepare discrete financial statements for these service lines, nor does it report such discrete operating results to its management. Read in the reply ↗

Tell us your consideration of providing liquidity disclosures to discuss the potential tax impact associated with the repatriation of undistributed earnings of foreign subsidiaries. We note that currently you have over $40 million in cash held in foreign banks. In this regard, please consider disclosing the impact of repatriating the undistributed earnings of foreign subsidiaries.

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In addition if you do not plan to repatriate the funds please disclose this in future filings. We refer you to Item 303(a)(1) of Regulation S-K and Section IV of SEC Release 33-8350.

The Company’s international business is growing and management intends to continue to grow the business in its foreign markets in the future through reinvestment of its foreign deposits and potential future earnings, such as through acquisitions of unrelated companies. Further, the Company maintains a large cash position in the United States while having little third-party debt to service, and the Company maintains adequate liquidity, and capital resources without regard to its foreign deposits to finance domestic operations and obligations and to fund expansion of its domestic business for

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the foreseeable future. Repatriation of cash from the Company’s foreign subsidiaries is not a part of the Company’s business plan. All of the Company’s foreign cash is held in Canadian bank accounts. In the future, the Company will revise its disclosure in its annual report on Form 10-K under “Management’s Discussion and Analysis of Financial Condition and Results of Operations — Liquidity and Capital Resource” to include the foregoing information.

The Company has authorized us to advise you that the Company acknowledges that:

· 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.

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