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 August 14, 2025

Gabriel Bruno
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, 2024
 File No. 000-01402
Dear Gabriel Bruno:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Indicators, page 18

1. We note your disclosure that orders, backlog, sales, inventory and
fill-rates are key
 operating measures utilized by the operating units to manage the company
as they
 provide key indicators of business trends. Please tell us what
consideration was given
 to disclosing these measures in MD&A, along with all the disclosures
consistent with
 the guidance in SEC Release No. 33-10751.
Results of Operations, page 19

2. We note your presentation of Adjusted EBIT by segment but you do not
include a
 discussion and analysis of each segment's Adjusted EBIT. Please revise.
Refer to Item
 303(b) of Regulation S-K.
 August 14, 2025
Page 2
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 6 - Segment information, page F-21

3. You indicate that the primary measure used by the chief operating
decision maker
 ( CODM ) is segment Adjusted EBIT; however, we note that you also
present gross
 profit and EBIT for each reportable segment. Tell us whether the CODM
receives
 gross profit and EBIT for each reportable segment and how they are used.
If the
 CODM uses more than one measure of segment profit or loss, such as gross
profit,
 EBIT and Adjusted EBIT, to assess segment performance and to decide how
to
 allocate resources, tell us which of the reported segment profit or loss
measures is
 required to be disclosed in accordance with ASC 280-10-50-28A. In this
regard, the
 measure required to be disclosed is that which management believes is
determined in
 accordance with the measurement principles most consistent with those
used in
 measuring the corresponding amounts in the consolidated financial
statements.
 Additional measures may be disclosed, with certain disclosures provided
for each
 related measure, pursuant to ASC 280-10-50-28A through 50-28C.
4. Please revise to reconcile the total of the reportable segments
amount for each
 measure of profit or loss to consolidated income before income taxes.
Refer to ASC
 280-10-50-30(b) and ASC 280-10-50-28C. The reconciliation should include
a single
 amount for the subtotal of the reportable segments measures of profit
or loss with a
 reconciliation of that amount to consolidated income before income
taxes. In this
 regard, we note that the segment note currently includes a
 Corporate/Elimination column which appears to result in the presentation
of non-
 GAAP measures of consolidated EBIT and consolidated Adjusted EBIT.
Please
 similarly revise to reconcile other total reportable segments amounts
to consolidated
 amounts, such as the total of the reportable segments assets to
consolidated assets.
 Refer to ASC 280-10-50-30.

 In closing, 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 Chen Chen at 202-551-7351 or Christine Dietz at
202-551-3408 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Jennifer Ansberry
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