SecProbe.io

Mail Stop 3030
June 4 , 2018

Via E -mail
Vincent K. Petrella
Chief Financial Officer
Lincoln Electric Holdings, Inc.
22801 St. Clair Avenue
Cleveland, Ohio 44117

Re: Lincoln Electric Holdings, Inc.
 Form 10 -K for the Fiscal Year Ended December 31, 2017
Filed February 27, 2018
File No.  000-01402

Dear  Mr. Petrella :

We have limited our review  of your filing  to the financial statements and related
disclosures 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
informa tion 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 December 31, 2017

Item7. Management’s Discussion and Analysis of Financial Condition and Results of Operations

Adjusted Earnings Before Interest and Income Taxes (“Adjusted EBIT”) , page 21

1. We note the tabular presentation of consolidated Adjusted EB IT and that amount as a
percentage of total sales on page 21.   Please revise future filings to include all of the
disclosures required by Item 10(e) of Regulation S -K for these non -GAAP
measures .  Refer to Qu estion 104.04 of the Non -GAAP Financial Measures Compliance
and Disclosure Interpretations.

Vincent K. Petrella
Lincoln Electric Holdings, Inc.
June 4 , 2018
Page 2

 Non-GAAP Financial Measures, page 22

2. Your presentation of adjusted net income presents special items on an after -tax
basis.   Please revise future filings and earnings releases to present the income tax effects
of your non -GAAP adjustments as a separate adjustment and clearly explain how it wa s
calculated.   Refer to Question 102.11 of the Non -GAAP Financial Measures Compliance
and Disclosure Interpretations.

Notes to Consolidated Financial Statements

Note 3 – Acquisitions, page F -16

3. You recognized a bargain purchase gain of $49.7 million on the $135.1 million
acquisition of Air Liquide Welding.   Describe to us, in sufficient detail, the reassessment
you performed pursuant to ASC 805 -30-25-4 before recognizing the gain on bargain
purchase.

Note 5 – Segment Information, page F -19

4. We note the line item “special items charge (gain)” in the tabular reconciliation of
segment profit as well as the explanatory footnotes included.   Please revise your
presentation in future filings to quantify by segment the charges described in the
footnotes.

We rem ind 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.

You may contact Eric Atallah  at (202) 551 -3663 or Lynn Dicker, Senior Accountant , at
(202) 551 -3616 with any questions.  You may also reach me at (202) 551 -3662.

Sincerely,

/s/ Lynn Dicker for

Kevin J. Kuhar
Accounting Branch Chief
Office of Electronics and Machinery