We examine the complete nucleotide sequences of the mitochondrial cytochrome oxidase II gene of 13 species of insects, representing 10 orders. The genes range from 673 to 690 bp in length, encoding 226 to 229 amino acids. Several insertion or deletion events, each involving one or two codons, can be observed. The 3' end of the gene is extremely variable in both length and sequence, making alignment of the ends unreliable. Using the first 639 nucleotide positions, for which unambiguous alignments could be obtained, we examine the neighbor-joining trees based on nucleotide divergences and based on conserved subsets of that data, including transversion and amino acid and second codon position divergences. Each of these subsets produces different trees, none of which can be easily reconciled with trees constructed using morphology and the fossil record. Bootstrap analysis using second codon positions strongly supports affinities between the order Blatteria (cockroaches) and the order Isoptera (termites) and between a wasp and the published honeybee sequence (Order Hymenoptera). The divergence of insect orders is very ancient and may have occurred too rapidly for easy resolution using mitochondrial protein sequences. Unambiguous resolution of insect orders will probably require analysis of many additional taxa, using the COII gene and other conserved sequences.