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Atlanta
Office
171
17th Street NW, Suite 2100
Atlanta, GA
30363-1031
Direct
phone: 404.873.8528
Direct
fax: 404.873.8529
E-mail:
stephen.fox@agg.com
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May 16,
2018
VIA EDGAR
Ms.
Kristi Marrone
United
States Securities and Exchange Commission
Division
of Corporation Finance
100 F
Street, N.E.
Washington,
DC 20549
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RE:
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Rollins,
Inc.
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File
No. 1-04422
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Form
10-K for the year ended December 31, 2017
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Dear
Ms. Marrone:
We are
legal counsel to Rollins, Inc. (the “Company”). This
letter provides the Company’s responses to the comments in
your letter dated May 4, 2018 about the Company’s referenced
filing. In an effort to facilitate the Staff’s review, we
have repeated the comments prior to setting forth the
Company’s response thereto.
Note 14. Employee Benefit Plans
Fair Value Measurements, page 53
1.
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.
The
Company will expand its disclosure in future filings to include a
description of the valuation techniques used in accordance with ASC
820-10-50-2bbb.
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Atlanta ● Washington D.C.
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Ms.
Kristi Marrone
May 16,
2018
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Page
2
Please
direct any further comments or questions to me at (404)
873-8528.
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Sincerely,
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ARNALL
GOLDEN GREGORY LLP
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/s/
Stephen D. Fox
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Stephen
D. Fox
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cc:
Mr. Paul Edward
Northen
Mr.
Edwin Page