Abstract: This paper relates the modern invective “topoi,” important in research on Cicero’s speeches, to ancient rhetorical theory as present in Cicero’s De inventione . A particular proximity is evident in the doctrine of indignatio , which lists loci communes in which “topoi” such as the tyrant or the sacrilegious are implicitly recognizable. I shall examine the relationship between the rules on loci communes and the “topos” of the sacrilegious in this paper, using Cicero’s speeches against Verres as an example: Impiety, a frequently ignored object of Cicero’s invectives, is thus brought into connection with his theoretical utterances. In doing so, I shall briefly discuss Verres’s depiction as a sacrilegious person in general and its references to other speeches of Cicero. Mainly, however, I focus on the use of the motif in the indignationes of the actio secunda in Verrem . Here, Cicero’s productive use of the teachings of Greek theory becomes apparent.