Mail Stop 3-8

      March 14, 2005




By Facsimile and U.S. Mail

Mr. Scott D. Farmer
President and Chief Executive Officer
Cintas Corporation
6800 Cintas Boulevard
Cincinnati, Ohio  45262-5737

      Re:    Form 10-K for the year ended May 31, 2004
                Form 10-Q for the quarter ended November 30, 2004
                File No.  0-11399

Dear Mr. Farmer:

      We have reviewed your response to our prior comments dated
November 19, 2004.  Our review resulted in the following
additional
comments.  All page references are keyed to the filings you
submitted
in electronic form on EDGAR.

FORM 10-K FOR THE YEAR ENDED MAY 31, 2004

Item 3.  Legal Proceedings, page 5

1. Please note that Item 103 of Regulation S-K requires, as
applicable, a discussion of any material pending litigation.
Please
also note that instruction 5.C. to Item 103 requires that you also
report any litigation in which a governmental authority is a party
to
a proceeding regarding the violation of a statute or regulation by
the discharge of materials into the environment, unless you have a
reasonable belief that the proceedings would result in no monetary
damages or in damages in an amount less than $100,000.  In this
regard, we are aware of the State of Connecticut`s legal
proceedings
concerning allegations that you violated the terms of your state
permit for the discharge of treated industrial laundry wastewater.
Please advise or revise your disclosure accordingly.

2. We also are aware of the Petition for Summary Enforcement of
Inspector General Subpoena filed on behalf of the United States
Postal Service on February 9, 2005 in the matter of United States
v.
Cintas Corporation.  Please advise us whether you should include
disclosure in response to Item 103 of Regulation S-K or revise
your
disclosure accordingly.

General

		We urge all persons who are responsible for the accuracy
and adequacy of the disclosure in the filing reviewed by the staff
to
be certain that they have provided all information investors
require
for an informed decision.  Since the company and its management
are
in possession of all facts relating to a company`s disclosure,
they
are responsible for the accuracy and adequacy of the disclosures
they
have made.

		In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

* the company is responsible for the adequacy and accuracy of the
disclosures 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.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in connection with our review
of
your filings or in response to our comments on your filings.

		Please send us your response to our comment within ten
days
from the date of this letter.  You should provide a cover letter
keying your response to our comment, and provide the requested
supplementary information, if any.  Where our comment requests you
to
revise future filings, we would expect that information to be
included in your next filing.  If you believe complying with our
comment is not appropriate, please tell us why in your letter.
Your
supplemental response should be submitted in electronic form on
EDGAR
as a correspondence file.  Refer to Rule 101 (a) of Regulation S-
T.



If you have any questions regarding our comment, please direct
them
to Scott Anderegg at (202) 942-2868, Staff Attorney, or in his
absence, to Ellie Quarles, Special Counsel, at (202) 942-1859.
Any
other questions regarding disclosure issues may be directed to me
at
(202) 942-2823.

							Sincerely,



							Michael Moran
							Accounting Branch Chief

??

??

??

??


Mr. Scott D. Farmer
Cintas Corporation
March 15, 2005
Page 1