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United States securities and exchange commission logo





                             September 16, 2021

       J. Michael Hansen
       Chief Financial Officer
       Cintas Corporation
       6800 Cintas Boulevard
       Cincinnati, OH 45262

                                                        Re: Cintas Corporation
                                                            Form 10-K for the
Fiscal Year Ended May 31, 2021
                                                            Filed July 28, 2021
                                                            File No. 000-11399

       Dear Mr. Hansen:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended May 31, 2021

       General

   1.                                                   We note that you
provided more expansive disclosure in your CSR report than you
                                                        provided in your SEC
filings. Please advise us what consideration you gave to providing
                                                        the same type of
climate-related disclosure in your SEC filings as you provided in your
                                                        CSR report.
   2.                                                   In your CSR report, you
state that you are committed to lowering the total amount of
                                                        energy that you consume
in your operations and reducing your greenhouse gas emissions.
                                                        Please revise your
disclosure to identify any material past and/or future capital
                                                        expenditures for
climate-related projects related to these initiatives. If material, please
                                                        quantify these
expenditures.
 J. Michael Hansen
FirstName  LastNameJ. Michael Hansen
Cintas Corporation
Comapany 16,
September  NameCintas
               2021    Corporation
September
Page 2     16, 2021 Page 2
FirstName LastName
3.       To the extent material, discuss the indirect consequences of
climate-related regulation or
         business trends, such as the following:

                decreased demand for goods or services that produce significant
greenhouse gas
              emissions or are related to carbon-based energy sources;
                increased demand for goods or services that result in lower
emissions than competing
              products;
                increased competition to develop innovative new services that
result in lower
              emissions; and
                any anticipated reputational risks resulting from operations or
products that produce
              material greenhouse gas emissions.
4.       If material, discuss the significant physical effects of climate
change on your operations
         and results. This disclosure may include the following:

                quantification of material weather-related damages to your
property or operations;
                potential for indirect weather-related impacts that have
affected or may affect your
              major customers or suppliers; and
                any weather-related impacts on the cost or availability of
insurance.
5.       Disclose the material effects of transition risks related to climate
change that may affect
         your business, financial condition, and results of operations, such as
policy and regulatory
         changes that could impose operational and compliance burdens, market
trends that may
         alter business opportunities, credit risks, or technological changes.

        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 Jennifer Angelini at 202-551-3047 or Sergio Chinos at
202-551-7844 with
any questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Manufacturing
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