United States securities and exchange commission logo June 16, 2023 Kenneth Krause Executive Vice President, Chief Financial Officer ROLLINS INC 2170 Piedmont Road, N.E. Atlanta, Georgia 30324 Re: ROLLINS INC Registration Statement on Form S-3 Filed June 5, 2023 File No. 333-272422 Dear Kenneth Krause: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Taylor Beech at 202-551-4515 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: David S. Huntington, Esq.