-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, U7UFgnlRa1axFAOq8Vi5vplEuevs6KP10i+ior6NK3XPDkI/mofF8u6iCriOAwuS iGbA/8/U2pXykOx801YEaA== 0000892251-06-000387.txt : 20061114 0000892251-06-000387.hdr.sgml : 20061114 20060517150211 ACCESSION NUMBER: 0000892251-06-000387 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060517 FILER: COMPANY DATA: COMPANY CONFORMED NAME: CINTAS CORP CENTRAL INDEX KEY: 0000723254 STANDARD INDUSTRIAL CLASSIFICATION: MEN'S & BOYS' FURNISHINGS, WORK CLOTHING, AND ALLIED GARMENTS [2320] IRS NUMBER: 311188630 STATE OF INCORPORATION: WA FISCAL YEAR END: 0531 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 6800 CINTAS BLVD STREET 2: P O BOX 625737 CITY: CINCINNATI STATE: OH ZIP: 45262 BUSINESS PHONE: 5134591200 MAIL ADDRESS: STREET 1: 6800 CINTAS BOULEVARD STREET 2: P O BOX 625737 CITY: CINCINNATI STATE: OH ZIP: 45262 CORRESP 1 filename1.htm SEC Comment Response Letter

May 17, 2006

United States Securities and
Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, DC 20549

Attention:    Michael Moran, Branch Chief

  Re: Cintas Corporation
Form 10-K for Fiscal Year Ended May 31, 2005
Filed August 15, 2005
File No. 0-11399

Ladies and Gentlemen:

This letter sets forth below the detailed responses of Cintas Corporation (the “Company”) to the comments of the Staff of the Commission in its letter to the Company dated April 17, 2006, with respect to the above referenced Form 10-K filing of the Company. In responding to the Staff’s comments, we have utilized the headings and numbering system in the Staff’s letter. This letter has been filed with the Commission as correspondence through EDGAR.

FORM 10-K FOR THE YEAR ENDED MAY 31, 2005

Notes to Consolidated Financial Statements, page 30
13.  Segment Information, page 41

SEC Comment #1

We note your response to comment 4 in our letter dated February 21, 2006. Please tell us each of the operating segments identified in accordance with paragraphs 10 through 15 of SFAS No. 131. Explain why the identified operating segments share both similar economic characteristics and a majority of the aggregation criteria and why aggregation into two reportable segments is permitted. See paragraph 4 of EITF 04-10. Please support your explanation with quantitative support for each operating segment to substantiate your conclusions. The provided information should include historical sales, margin and operating profit figures for the recent five year period.


Response

Cintas’ products and services are designed to enhance our customers’ images and brand identification as well as provide a safe and efficient work place. Our products are sold through two business models: a contractual, regular recurring rental business with a significant service component and a direct sale, order fulfillment, distribution business. The use of each model is determined by customers’ decisions to rent or buy, with many customers requiring elements of both. These two business models provide the basis for our two reportable operating segments: Rentals and Other Services.

Our Rentals reportable operating segment is predominantly the rental and delivery of uniforms, mats, mops, towels, restroom and hygiene services, cleanroom garments and flame resistant clothing to our customers. These products and services are provided to our customers on a contractual basis and are delivered through our Rentals route distribution network, typically on a weekly basis.

The Other Services reportable operating segment consists primarily of the direct sale of garments, first aid products, fire protection products, safety products and branded promotional products. Unlike the Rentals operating segment, there are few service agreements with these customers. The business model in this reporting segment is a direct sale, order fulfillment, distribution business, where the fundamental focus is on the sourcing, the warehousing and the distribution of products. While our product offering within this reporting segment may change from time to time (i.e., addition of new safety products, replacement of garment styles, etc.), the nature of the products do not change. That is, the products selected continue to promote image and safety in the workplace. In addition, the business model and the production process do not change with any differentiation in product offerings. We focus on the fundamentals of sourcing, warehousing and distribution, regardless of the product offering.

The following is our evaluation for defining our reportable operating segments in accordance with SFAS No. 131 (SFAS 131), Disclosures about Segments of an Enterprise and Related Information.

We have eight business units which supply image and safety products and services to our customer base. They are as follows:

  Rentals
  Uniform Sales
  First Aid & Safety Sales
  Catalog Sales
  Fire Protection Sales
  Sourcing and Distribution
  Document Management Sales
  Government Sales


Determination of Operating Segments

SFAS 131 defines operating segments in paragraphs 10 through 15. SFAS 131 paragraph 10 defines an operating segment as a component of an enterprise that a.) engages in business activities from which it may earn revenues and incur expenses, b.) whose operating results are regularly reviewed by the enterprise’s chief operating decision maker (“CODM”) to make decisions about resources to be allocated to the segment and assess its performances and c.) for which discrete financial information is available.

The following reflects our assessments of each business unit with respect to paragraph 10. A “Yes” denotes that the particular business unit meets the referenced criteria.

Business Unit
Criteria A
Earn Revenue,
Incur Expenses

Criteria B
Oper. Results Regularly
Reviewed by CODM

Criteria C
Discrete Financial
Information Available

Rentals Yes Yes Yes
 
Uniform Sales Yes Yes Yes
 
First Aid & Safety Sales Yes Yes Yes
 
Catalog Sales Yes Yes Yes
 
Fire Protection Sales Yes Yes Yes
 
Sourcing and Distribution No
See Note 1
Yes
See Note 1
Yes
 
 
Document Management Sales Yes Yes Yes
 
Government Sales Yes Yes Yes

Note 1 – Sourcing and Distribution does not earn revenue. Its primary function is to source and distribute product to the Uniform, First Aid & Safety, Catalog and Fire Protection sales business units. The operating results regularly reviewed by the chief operating decision maker for Sourcing and Distribution relate to operational measurements such as cost per unit.

SFAS 131 paragraph 11 indicates that not every part of an enterprise is necessarily an operation segment or part of an operating segment. Our corporate financing (i.e., interest income and interest expense) is not considered to be an operating segment. As such, it is reported as “Corporate” in our segment reporting disclosure.


SFAS 131 paragraphs 12 and 14 define the terms CODM and segment manager. In accordance with those definitions, we note the following as CODM(s) and Segment Manager(s) for each business unit.

Business Unit
CODM(s)
Segment Manager
Rentals Scott D. Farmer, CEO
and
John W. Milligan,
  John W. Milligan, President & COO, Rental Division
and
  President & COO, Rental Division 14 Vice Presidents
 
Uniform Sales Scott D. Farmer, CEO William L. Cronin,
    President & COO, National Account
    Division
 
First Aid & Safety Sales Scott D. Farmer, CEO David Pollak, Jr.,
    President & COO, First Aid & Safety
    Division
 
Catalog Sales Scott D. Farmer, CEO William W. Goetz,
    Vice President, Marketing &
    Merchandising
 
Fire Protection Sales Scott D. Farmer, CEO David Pollak, Jr.,
    President & COO, First Aid & Safety
    Division
 
Sourcing and Distribution Scott D. Farmer, CEO Kevin M. Bien,
  and Vice President, Global Sourcing
  J. Phillip Holloman, and
  Sr. Vice President, Global Supply Laura J. Hendricks,
  Chain Management Vice President, Distribution &
  and Six Sigma Production Planning
 
Document Management Sales Scott D. Farmer, CEO Todd M. Schneider,
    Vice President, Document Management
    Division
 
Government Sales Scott D. Farmer, CEO David Warns,
  and Director of Government Operations
  William L. Cronin, President & COO,  
  National Account Division  

Scott D. Farmer, CEO, is the CODM for all Cintas business units. Several business units have an additional CODM due to size of operations, span of control, or business unit complexities or uniqueness.

SFAS 131 paragraph 13 discusses situations where the three characteristics of operating segments, as described in paragraph 10, do not clearly identify a single set of operating segments. In Cintas’ case, however, the three characteristics of operating segments described in paragraph 10 do clearly identify a single set of operating segments. As such, we do not evaluate additional factors.


SFAS 131 paragraph 15 describes situations involving matrix forms of organizations. This paragraph does not apply, since Cintas did not have a matrix form of organization.

Based on our evaluation of the Cintas business units with respect to SFAS 131 paragraphs 10 through 15, we conclude that we have seven operating segments. They are as follows.

  Rentals
  Uniform Sales
  First Aid & Safety Sales
  Catalog Sales
  Fire Protection Sales
  Document Management Sales
  Government Sales

Determination of Reportable Operating Segments

In determining the reportable operating segments, which are required to be reported in the footnotes to our financial statements, we perform the following steps.

  1. We determine which operating segments meet the quantitative thresholds as described in paragraph 18 of SFAS 131 (i.e., the 10% tests). Operating segments, or the aggregation of operating segments, that meet the quantitative thresholds are reportable.
  2. We determine which operating segments meet the aggregation criteria as described in paragraph 17 of SFAS 131 and EITF 04-10. The operating segments that meet the aggregation criteria can be aggregated for purposes of determining whether the aggregated segments meet the quantitative thresholds. Operating segments, or the aggregation of operating segments, that meet the quantitative thresholds are reportable.
  3. We test whether the reportable segments contribute at least 75% of total consolidated revenue. If they do not, additional operating segments that do not individually meet the quantitative thresholds must be reported to reach the 75% of consolidated revenue.
  4. We evaluate the need for an “All Other” category, grouping operating segments that are not individually reportable and that do not share a majority of the aggregation criteria with another operating segment.

The Rentals operating segment meets the quantitative criteria described in step #1 above and is therefore an individually reported operating segment. Quantitative financial information for the Rentals operating segment, including historical sales, margin and profit figures for the last five year period, is included as Exhibit I to this letter.

The Uniform Sales operating segment, the First Aid and Safety Sales operating segment, the Catalog Sales operating segment and the Fire Protection Sales operating segment each do not meet the quantitative levels described in #1 above (i.e., they do not meet the 10% tests). Quantitative financial information for each of these operating segments, including historical sales, margin and profit figures for the last five year period, is included as Exhibit II to this letter.

These four operating segments combine to form our direct sale, order fulfillment, distribution business (the “direct sale operating segments”) and follow the same business model. Sourcing and Distribution is an integral part of this model. As such, we have included its financial


information on Exhibit II with that of the four direct sale operating segments. The direct sale operating segments share economic characteristics and the aggregation criteria and are therefore aggregated into one reportable operating segment (Other Services) as provided for in paragraph 17 of SFAS 131. An analysis of the similarity of economic characteristics and the aggregation criteria of paragraph 17 follows:

Economic Characteristics

Evidence of similar economic characteristics for these operating segments is provided on Exhibit II. With two exceptions, for each of the five years presented, gross margins fall within a 5% range and selling and administrative expenses fall within a 4% range. The only exceptions are in FY2002, when our entire business was dramatically affected by the terrorist events of 9/11, and in fire protection for FY2003, as we first introduced fire protection products at the end of that fiscal year. In addition to sharing economic characteristics, the products and services provided within the Other Services reportable operating segment share the aggregation criteria described in SFAS 131 paragraphs 17 (a-e) as outlined below:

a.    Nature of Products and Services

The nature of products and services in each of the direct sale operating segments is similar. The products provided are all designed to meet our strategic goal of both enhancing our customers’ image and safety in the workplace. Certainly, the individual products in these operating segments have different physical characteristics (i.e., garments, mats, first aid supplies, fire extinguishers, etc.). However, the nature and focus of the products remains the same: they are products sold to and used by business customers to enhance their image and brand identity and to improve safety and efficiency at their facilities.

b.    Nature of Production Processes

The nature of the production processes within these operating segments is similar, consisting of the design, identification and sourcing of high quality products.

Once we identify products and product specifications are determined, our centralized supply chain department makes sourcing decisions (i.e., make or buy) based primarily on required volume levels, timeliness of deliveries, branding requirements and exclusive design needs. These decisions lead to supplier selection. Our supply chain department then manages supplier relationships to ensure that specifications are met, price points remain competitive and quality production continues. The nature of this production process remains consistent regardless of our direct sale product offering.

c.    Type or Class of Customer

The type or class of customer being serviced by the products in the direct sale operating segments is a broad class of customer in line with our goal of enhancing our customers’ images and brand identification as well as providing them a safe and efficient work place. We view every business in the United States and Canada as a potential customer for each direct sale operating segment and indeed have customers in most SIC codes in this segment (as well as in our Rentals segment). Our marketing data indicates that our direct sale operating segments share 17 of the top 20 SIC codes, demonstrating not only the diversity of our customer base but also the similar nature of our customers in each of the direct sale operating segments.


d.    Methods and Distribution

The methods of distribution within these direct sale operating segments are similar. Our distribution function consists of warehousing these products primarily through our distribution network, managing inventory levels and then delivering these products to our customers’ place of business in the most cost efficient manner, including direct delivery through a local representative and/or a local delivery route.

e.    Nature of Regulatory Environment

While we sell products and provide services to many regulated industries, our business of providing the products in each of the direct sale operating segments is not considered heavily regulated.

A summary of the aggregation criteria follows.

Uniform
Sales

First Aid & Safety
Sales

Catalog
Sales

Fire Protection
Sales

Nature of Product Sale of Uniform and Sale of First Aid and Sale of Uniform and Sale of Fire
  Promotional Products Safety Products Safety Products Extinguishers and
        other Fire Protection Products
        and Services
 
Nature of Customers All SIC Codes; All SIC Codes; All SIC Codes; All SIC Codes;
  All Sizes All Sizes All Sizes All Sizes
 
Nature of Product Product Identification; Product Product
Production Process Identification; Centralized Identification; Identification;
  Centralized Sourcing Sourcing & Supply Centralized Sourcing Centralized Sourcing
  & Supply Chain Chain & Supply Chain & Supply Chain
  Management Management Management Management
 
Nature of From Dist. Center to From Dist. Center From Dist. Center to From Dist. Center or
Distribution customer directly or to customer customer directly or local warehouse to
  through local directly or through through local customer directly or
  representative local route route through local route
 
Regulatory No significant No significant No significant No significant
Environment regulatory regulatory regulatory regulatory
  environment environment environment environment

In essence, our business model of direct sale with a focus on sourcing, warehousing and distribution of products allows us to employ a common methodology across product lines that are united in the strategic goal of enhancing our customers’ image and safety in the workplace. Because these operating segments share the aggregation criteria as well as economic characteristics, they are aggregated into our Other Services reportable operating segment.


Our Document Management Sales operating segment does not meet the quantitative criteria described in paragraph 18 of SFAS 131 (it does not meet any of the 10% tests), as shown on Exhibit III. The Document Management Sales operating segment also does not meet the aggregation criteria in step #2. Its economic characteristics are not similar to, and the nature of the production process and distribution process are not shared with, other operating segments. We have incorporated this operating segment into Other Services due to its immaterial size (approximately 1% of Cintas’ consolidated revenue) and because it is more consistent with the operating segments aggregated into Other Services as compared to the Rentals operating segment. We will continue to challenge the placement of Document Management Sales as this business develops and grows in future years.

Our Government Sales operating segment also does not meet the quantitative criteria described in paragraph 18 of SFAS 131 (it does not meet any of the 10% tests), as shown on Exhibit IV. The Government Sales operating segment also does not meet the aggregation criteria in step #2. While the economic characteristics are similar to the operating segments aggregated into the Other Services reportable operating segment, the nature of its customers, the nature of the production process and the nature of distribution are not. This operating segment sells strictly to the government sector, with approximately 92% of its revenues being generated from sales to the United States Postal Service. The business is run from a separate distribution facility in Kansas City that is not part of our centralized distribution business unit. The customer has unique product requirements, including union sourcing and manufacturing. Additionally, a large portion of this business is sold by independent representatives. We have incorporated this operating segment into Other Services due to its immaterial size (less than 1% of Cintas’ consolidated revenue) and because it is more consistent with the operating segments aggregated into Other Services as compared to the Rentals operating segment. We will continue to challenge the placement of Government Sales as this business develops and grows in future years.

As noted above, after considering the quantitative thresholds and aggregation criteria, our third step is the determination of the adequacy of our reportable operating segments by combining the revenue for the Rentals reportable operating segment (77% of total consolidated revenues for FY2005) and the revenue for the Other Services reportable operating segment (23% of total consolidated revenues for FY2005). Since our reportable segments exceed 75% of our consolidated revenue, we have met the requirements of paragraph 20 of SFAS 131 and no additional operating segments are identified for separate reporting.

We do not employ an “All Other” category as described in our Step #4 above. A corporate segment is provided depicting interest income and interest expense. Since the Document Management Sales and the Government Sales operating segments are immaterial, they are included in the Other Services reportable operating segment as described above.

In conclusion, based on our continued analysis of reportable operating segments as defined in SFAS 131, it is appropriate for us to continue to provide disclosure for two reportable operating segments: Rentals and Other Services. A financial reconciliation of the Other Services reportable operating segment is included as Exhibit V. The Rentals reportable operating segment is provided as Exhibit I.


If the Staff of the Commission have any questions or comments concerning the above response or desires any additional supplemental information, please contact me by phone at 513-573-4211, by fax at 513-573-4030, or by e-mail at galeb@cintas.com.

Sincerely,


/s/William C. Gale
William C. Gale
Chief Financial Officer

cc: Scott D. Farmer
Chief Executive Officer


EXHIBIT I
(in thousands)

Rentals Reportable Operating Segment

FY 2005
FY 2004
FY 2003
FY 2002
FY 2001
Revenue   $2,363,397   $2,201,405   $2,101,785   $1,753,368   $1,610,606  
 
Gross margin  $1,067,405   $   978,767   $   928,119   $   800,016   $   714,067  
   45.2%   44.5%   44.1%   45.6%   44.3%  
 
Selling and administrative expenses  $   633,488   $   581,380   $   555,748   $   451,097   $   391,522  
   26.8%   26.4%   26.4%   25.7%   24.3%  
 
Operating income  $   433,917   $   397,387   $   372,371   $   348,919   $   322,545  
   18.4% 18.1%   17.7%   19.9%   20.0%  

EXHIBIT II
(in thousands)

Direct Sale Operating Segments
Fiscal Year 2005

Uniform Sales
First Aid & Safety
Sales

Catalog Sales
Fire Protection
Sales

Sourcing and
Distribution

Revenue   $290,293   $150,641   $135,799   $68,012   $      453  
 
Gross margin  $105,101   $  60,386   $  49,773   $23,814   ($32,461 )
   36.2%   40.1%   36.7%   35.0%   -7165.8%  
 
Selling and admin expenses  $  83,300   $  40,548   Note 1   $17,439   $ 14,176  
   28.7%   26.9%       25.6%   3129.3%
 
Operating income  $  21,801   $  19,838   $  49,773   $  6,375   ($46,637 )
   7.5%   13.2%   36.7%   9.4%   -10295.1%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT II
(in thousands)

Direct Sale Operating Segments
Fiscal Year 2004

Uniform Sales
First Aid & Safety
Sales

Catalog Sales
Fire Protection Sales
Sourcing and Distribution
Revenue   $282,790   $133,283   $134,905   $21,673   $      135  
 
Gross margin  $102,436   $  53,050   $  47,688   $  7,611   ($21,961 )
   36.2%   39.8%   35.3%   35.1%   -16267.4%  
 
Selling and admin expenses  $  76,344   $  36,005   Note 1   $  5,334   $ 15,085  
   27.0%   27.0%       24.6%   11174.1%
 
Operating income  $  26,092   $  17,045   $  47,688   $  2,277   ($37,046 )
   9.2%   12.8%   35.3%   10.5%   -27441.5%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT II
(in thousands)

Direct Sale Operating Segments
Fiscal Year 2003

Uniform Sales
First Aid & Safety
Sales

Catalog Sales
Fire Protection
Sales

Sourcing and
Distribution

Revenue   $280,787   $119,694   $    137,250   $806   $   9,814  
 
Gross margin  $104,307   $  48,036   $      50,788   $341   ($27,769 )
   37.1%   40.1%   37.0%   42.3%   -283.0%  
 
Selling and admin expenses  $  77,339   $  33,083   Note 1   $175   $ 19,308  
   27.5%   27.6%       21.7%   196.7%  
 
Operating income  $  26,968   $  14,953   $      50,788   $166   ($47,077 )
   9.6%   12.5%   37.0%   20.6%   -479.7%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT II
(in thousands)

Direct Sale Operating Segments
Fiscal Year 2002

Uniform Sales
First Aid &
Safety
Sales

Catalog Sales
Fire Protection Sales
Sourcing and
Distribution

Revenue   $248,309   $105,876   $124,274   --   $   9,581  
 
Gross margin  $  80,801   $  42,663   $  48,997   --  ($27,607 )
   32.5%   40.3%   39.4%      -288.1%  
 
Selling and admin expenses  $  66,086   $  30,778   Note 1   --  $ 22,454  
   26.6%   29.1%          234.4%  
 
Operating income  $  14,715   $  11,885   $  48,997   --  ($50,061 )
   5.9%   11.2%   39.4%      -522.5%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT II
(in thousands)

Direct Sale Operating Segments
Fiscal Year 2001

Uniform Sales
First Aid & Safety
Sales

Catalog Sales
Fire Protection Sales
Sourcing and
Distribution

Revenue   $291,469   $98,591   $121,330   --   $   5,931  
 
Gross margin  $113,740   $41,904   $  50,310   --  ($37,850 )
   39.0%   42.5%   41.5%      -638.2%  
 
Selling and admin expenses  $  85,516   $28,313   Note 1   --  $ 14,078  
   29.3%   28.7%          237.4%  
 
Operating income  $  28,224   $13,591   $  50,310   --  ($51,928 )
   9.7%   13.8%   41.5%      -875.6%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT III
(in thousands)

Document Management Sales Operating Segment

FY 2005
FY 2004
FY 2003
FY 2002
FY 2001
Revenue   $31,895   $12,457   $2,324   --   --  
 
Gross margin  $19,794   $  7,715   $1,558   --  -- 
   62.1%   61.9%   67.1%        
 
Selling and administrative expenses  $13,670   $  5,777   $   883   --  -- 
   42.9%   46.4%   38.0%        
 
Operating income  $  6,124   $  1,938   $   675   --  -- 
   19.2%   15.5%   29.1%        

EXHIBIT IV
(in thousands)

Government Sales Operating Segment

FY 2005
FY 2004
FY 2003
FY 2002
FY 2001
Revenue   $26,793   $27,411   $34,125   $29,644   $32,773  
 
Gross margin  $10,947   $11,186   $13,828   $12,500   $14,096  
   40.9%   40.8%   40.5%   42.2%   43.0%  
 
Selling and administrative expenses  $  7,611   $  7,693   $  8,901   $10,054   $  9,635  
   28.4%   28.1%   26.1%   33.9%   29.4%  
 
Operating income  $  3,336   $  3,493   $  4,927   $  2,446   $  4,462  
   12.5%   12.7%   14.4%   8.2%   13.6%  

EXHIBIT V
(in thousands)

Other Services Reportable Operating Segment
Fiscal Year 2005

Uniform Sales
First Aid &
Safety Sales

Catalog
Sales

Fire
Protection
Sales

Government
Sales

Sourcing
and
Distribution

Document
Management Sales

Total
Revenue   $290,293   $150,641   $    135,799   $68,012   $26,793   $      453   $31,895   $703,886  
 
Gross margin  $105,101   $  60,386   $      49,773   $23,814   $10,947   ($32,461 ) $19,794   $237,354  
   36.2%   40.1%   36.7%   35.0%   40.9%   -7165.8%   62.1%   33.7%  
 
Selling and admin expenses  $  83,300   $  40,548   Note 1   $17,439   $  7,611   $ 14,176   $13,670   $176,744  
   28.7%   26.9%       25.6%   28.4%   3129.3%   42.9%   25.1%  
 
Operating income  $  21,801   $  19,838   $      49,773   $  6,375   $  3,336   ($46,637 ) $  6,124   $  60,610  
   7.5%   13.2%   36.7%   9.4%   12.5%   -10295.1%   19.2%   8.6%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT V
(in thousands)

Other Services Reportable Operating Segment
Fiscal Year 2004

Uniform Sales
First Aid &
Safety
Sales

Catalog
Sales

Fire
Protection
Sales

Government
Sales

Sourcing
and Distribution

Document
Management
Sales

Total
Revenue   $282,790   $133,283   $    134,905   $21,673   $27,411   $      135   $12,457   $612,654  
 
Gross margin  $102,436   $  53,050   $      47,688   $  7,611   $11,186   ($21,961 ) $  7,715   $207,725  
   36.2%   39.8%   35.3%   35.1%   40.8%   -16267.4%   61.9%   33.9%  
 
Selling and admin expenses  $  76,344   $  36,005   Note 1   $  5,334   $  7,693   $ 15,085   $  5,777   $146,238  
   27.0%   27.0%       24.6%   28.1%   11174.1%   46.4%   23.9%  
 
Operating income  $  26,092   $  17,045   $      47,688   $  2,277   $  3,493   ($37,046 ) $  1,938   $  61,487  
   9.2%   12.8%   35.3%   10.5%   12.7%   -27441.5%   15.5%   10.0%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT V
(in thousands)

Other Services Reportable Operating Segment
Fiscal Year 2003

Uniform Sales
First Aid &
Safety
Sales

Catalog
Sales

Fire
Protection
Sales

Government
Sales

Sourcing
and Distribution

Document
Management
Sales

Total
Revenue   $280,787   $119,694   $    137,250   $806   $34,125   $   9,814   $2,324   $584,800  
 
Gross margin  $104,307   $  48,036   $      50,788   $341   $13,828   ($27,769 ) $1,558   $191,089  
   37.1%   40.1%   37.0%   42.3%   40.5%   -283.0%   67.1%   32.7%  
 
Selling and admin expenses  $  77,339   $  33,083   Note 1   $175   $  8,901   $ 19,308   $   883   $139,689  
   27.5%   27.6%       21.7%   26.1%   196.7%   38.0%   23.9%  
 
Operating income  $  26,968   $  14,953   $      50,788   $166   $  4,927   ($47,077 ) $   675   $  51,400  
   9.6%   12.5%   37.0%   20.6%   14.4%   -479.7%   29.1%   8.8%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT V
(in thousands)

Other Services Reportable Operating Segment
Fiscal Year 2002

Uniform Sales
First Aid &
Safety
Sales

Catalog
Sales

Fire
Protection
Sales

Government
Sales

Sourcing
and Distribution

Document
Management Sales

Total
Revenue   $248,309   $105,876   $124,274   --   $29,644   $   9,581   --   $517,684  
 
Gross margin  $  80,801   $  42,663   $  48,997   --   $12,500   ($27,607 ) --   $157,354  
   32.5%   40.3%   39.4%       42.2%   -288.1%       30.4%  
 
Selling and admin expenses  $  66,086   $  30,778   Note 1   --   $10,054   $ 22,454   --   $129,372  
   26.6%   29.1%           33.9%   234.4%       25.0%  
 
Operating income  $  14,715   $  11,885   $  48,997   --   $  2,446   ($50,061 ) --   $  27,982  
   5.9%   11.2%   39.4%       8.3%   -522.5%       5.4%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.


EXHIBIT V
(in thousands)

Other Services Reportable Operating Segment
Fiscal Year 2001

Uniform Sales
First Aid &
Safety
Sales

Catalog
Sales

Fire
Protection
Sales

Government
Sales

Sourcing
and
Distribution

Document
Management Sales

Total
Revenue   $291,469   $98,591   $121,330   --   $32,773   $   5,931   --   $550,094  
 
Gross margin  $113,740   $41,904   $  50,310   --   $14,096   ($37,850 ) --   $182,200  
   39.0%   42.5%   41.5%       43.0%   -638.2%       33.1%  
 
Selling and admin expenses  $  85,516   $28,313   Note 1   --   $  9,634   $ 14,078   --   $137,541  
   29.3%   28.7%           29.4%   237.4%       25.0%  
 
Operating income  $  28,224   $13,591   $  50,310   --   $  4,462   ($51,928 ) --   $  44,659  
   9.7%   13.8%   41.5%       13.6%   -875.6%       8.1%  

Note 1: Discrete selling and administrative information is not allocated from the Rentals operating segment due to the subjective nature that these calculations would require.

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