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SEC Response Letter

 Lincoln Electric Holdings, Inc.

22801 St. Clair Avenue

Cleveland, Ohio 44117

May 12, 2010

 Mr. Jay Webb

 Reviewing Accountant

 United States
Securities and Exchange Commission

 Division of Corporate Finance, Mail Stop 3030

100 F Street, N.E.

 Washington, DC 20549-6010

Attention:

Geoff Kruczek

Jay Mumford

Julie Sherman

RE:

Lincoln Electric Holdings, Inc.

Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2009

Filed February 22, 2010

File No. 000-1402

 Dear Mr. Webb,

In connection with the Staff’s review of our Annual Report on Form 10-K for the year ended December 31, 2009, we have the following responses
for your consideration. For ease of reference, the text of the Staff’s comments is set forth followed by our response.

 SEC Comment
1:  (Customers, page 2)

 Please ensure that your disclosure in applicable future filings consistently and clearly
addresses the extent to which your business, including each segment, is seasonal. In this regard, you state on page 3 that your “business is not seasonal,” which appears to be inconsistent with managements’ statement in your
4th quarter earnings call that “typically our
fourth-quarter sales are considerably weaker than our third quarter.” Please refer to Items 101(c)(1)(v) of Regulation S-K and, as applicable to future filings, Instruction 5 to Item 303 (b) of Regulation S-K.

Response 1: We acknowledge the Staff’s comment and will discuss the seasonal aspects of our business in future filings to the extent
applicable.

 SEC Comment 2:  (Item 7. Management’s Discussion and Analysis…, page 13, 2009 Compared to
2008, page 15)

 In applicable future filings, please expand the comparative disclosure you provide regarding your results of
operation to explain the reasons underlying the changes you note. For example, in future filings, please expand to disclose the causes for the increases or decreases to price and volume. For

example, did prices and volume decrease as a result of decreased demand? Did you implement price increases for your products and, if so, what impact did those increase have?

Response 2: We acknowledge the Staff’s comment and will expand future disclosures in Results of Operations for Item 7. Management’s
Discussion and Analysis of Financial Condition and Results of Operations to explain the reasons underlying changes that we note, including the causes for the increases or decreases to price and volume, such as changes in demand and changes to
product pricing.

 SEC Comment 3:   (Item 10. Directors, Executive Officers and Corporate Governance, page 35)

 We note the statement on page 21 of your definitive proxy statement that you have satisfied disclosure requirements regarding amendments and
waivers from your Code of Corporate Conduct and Ethics by posting such information on your website. Please tell us how you satisfied the disclosure requirements you mention. Provide us with copies of the material you posted.

Response 3:   We have not granted any waivers from any provision of our Code of Corporate Conduct and Ethics (“Code of
Conduct”) that applies to our principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, that relates to any element of the code of ethics definition as set
forth in Item 406(b) of Regulation S-K. We amended and restated our Code of Conduct in August 2007 to provide for certain organizational changes relating to our corporate compliance program (namely, the addition of a Director of Compliance).
Additionally, in the fall of 2009, we updated the design and style of our Code of Conduct documentation. In each case, the amended and restated Code of Conduct was promptly posted on the Company’s website. Other than the amended and restated
Code of Conduct, there was no other material posted or required to be posted on the Company’s website in connection with the amendments. Per your request, please find attached our current Code of Conduct, in English, as made available on the
Company’s website.

 SEC Comment 4:   (Item 11. Executive Compensation, page 35)

We note the disclosure on pages 30 and 31 of your definitive proxy statement regarding the services provided by and fees paid to Towers Watson. Please
tell us, and revise future filings to clarify, whether the decision to engage Towers Watson for the “additional services” was made or recommended by management.

Response 4: The decision to engage Towers Watson for services other than executive compensation services was recommended by management and
reviewed and approved by the Compensation and Executive Development Committee of the Board (the “Committee”).

 SEC Comment
5:   (Item 11. Executive Compensation, page 35)

 Your disclosure on page 31 of your definitive proxy statement that
Towers Watson “will continue” to provide executive compensation and other services to management implies that it provided such services during 2009. If so, please tell us and revise future filings to clarify why the services provided to
management and fees paid for those services are not included in your disclosure. Refer to Item 407(e)(3)(iii) of Regulation S-K.

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 Response 5:    We have provided the information noted above on page 31 of the
Company’s 2010 definitive proxy statement. The Company paid Towers Watson $481,344 for non-executive compensation services and $239,910 for executive compensation services for 2009.

SEC Comment 6: (Financial Statements, page F-1, Report of Independent Registered Public Accounting Firm, page F-1)

We note that your auditors’ reports on both your financial statements and internal control over financial reporting did not indicate the location of
the audit firm that performed the audit. Please amend your December 31, 2009 Form 10-K to include auditor reports that indicate the city and state where the reports were issued. Refer to the guidance at Rule 2-02(a) of Regulation S-X.

 Response 6: We acknowledge the Staff’s comment and will ensure that our auditor’s reports include the city and state of
issuance in future filings. The city and state were inadvertently omitted from the final draft of the auditor’s reports. We respectfully request to make this correction in future filings and to not amend our December 31, 2009 Form 10-K.

 SEC Comment 7: (Notes to Consolidated Financial Statements, page F-8, Note 1 – Significant Accounting Policies, page
F-8, Revenue Recognition, page F-11)

 We see your disclosure that revenue is recognized when the risks and rewards of ownership and title
to the product have transferred to the customer and in accordance with shipping terms, which is generally at the point of shipment. Please tell us and expand future filings, including any amendments, to describe your revenue recognition policy in
greater detail. For example, to the extent that your policies differ among customer categories and among the various marketing venues used by the Company, i.e. distributors and reseller, please include a detail discussion of such policies in this
footnote. Also, if your revenue recognition policies vary in different parts of the world those policies should be discussed. Finally, provide details of discounts, return policies, post shipment obligations, customer acceptance, warranties,
credits, rebates, and price protection or similar privileges and how they impact revenue recognition.

 Response 7: Revenue is
recognized when the risks and rewards of ownership and title to the product have transferred to the customer and in accordance with shipping terms, which is generally at the point of shipment. We also utilize other shipping terms that result in the
transfer of title at other points in the delivery process. In these cases, revenue is also recognized when title has transferred (e.g., customer destination). This policy applies to approximately 98% of our consolidated Net sales and is consistent
for all customers and marketing venues around the world.

 Customers and Marketing Venues - The Company’s products are sold in both
domestic and international markets. In North America, products are sold principally through industrial distributors, retailers and also directly to users of welding products. Outside of North America, the Company has an international sales
organization comprised of Company employees and agents who sell products from the Company’s various manufacturing sites to distributors and product users. For all customer categories and marketing venues, revenue is recognized when the risks
and rewards of ownership and title to the product have transferred to the customer and in accordance with shipping terms, which is generally at the point of shipment. The Company’s revenue recognition policies are consistent around the world.

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 Discounts - Product pricing is generally based on standard price lists. Where discounts off of list price
are authorized, such discounts are recognized as a reduction of Sales to arrive at Net sales at the time revenue is recognized.

 Return
Policies - Product returns, in accordance with established return policies, are recorded as a reduction of Sales to arrive at Net sales as transactions occur. In addition, we perform calculations of estimated sales returns based on historical sales
return experience in relation to sales. Based on this experience, we believe future sales returns can be reasonably estimated. Accordingly, we believe it is appropriate to make estimates of expected sales returns and accrue for such estimates as
sales returns allowances. Sales returns allowances are recognized as a reduction of Sales to arrive at Net sales at the time revenue is recognized.

Post Shipment Obligations - The Company’s primary post shipment obligations are product warranty claims. The costs of warranty claims are estimated
based on historical data and recognized at the time revenue is recognized. In certain limited situations we provide installation and training services that occur after we ship our product to the customer. Revenue recognition for these orders, which
accounted for approximately 1% of Net sales in 2009, occurs when customer acceptance is obtained.

 Customer Acceptance - As noted above, in
certain limited situations we provide installation and training services that occur after we ship our product to the customer. We recognize revenue for these orders upon customer acceptance which occurs after installation and training have been
completed. The revenue from these orders accounted for approximately 1% of Net sales in 2009.

 Warranties - As disclosed in Note 1 -
Significant Accounting Policies, on page F-11, we accrue for product warranty claims costs based on historical warranty experience in relation to sales. Warranty costs are charged to Cost of goods sold at the time the related revenue is recognized
and do not affect revenue recognition.

 Credits - Sales credits may be offered to customers to settle customer disputes and other possible
issues that arise from time to time. Similar to product returns noted above, actual customer sales credits are recorded as a reduction of Sales to arrive at Net sales as transactions occur. In addition, customer sales credits are estimated based on
historical customer sales credits experience in relation to sales. Based on this experience, we believe future customer sales credits can be reasonably estimated. Accordingly, we believe it is appropriate to make estimates of expected customer sales
credits and accrue for such estimates. Customer sales credits are included in sales returns allowances and are recognized as a reduction of Sales to arrive at Net sales at the time the related revenue is recognized.

Rebates - From time to time, we may offer rebates and incentive programs to our customers. The estimated costs of our rebates and incentive programs are
recognized over the program period based on actual sales and are recorded as a reduction of Sales to arrive at Net sales. Historical sales volumes and our experience with previous rebates and incentive programs give us a reasonable basis for
recording the estimated costs of the rebates and incentive programs at the time revenue is recognized.

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 Price Protection - We do not offer price protection or similar privileges to our customers.

Acknowledging the Staff’s comment, we propose to expand our revenue recognition policy discussion in future filings as follows:

“The Company recognizes revenue when the risks and rewards of ownership and title to the product have transferred to the customer which generally
occurs at point of shipment. The Company recognizes any discounts, credits, returns, rebates and incentive programs based on reasonable estimates as a reduction of Sales to arrive at Net sales at the same time the related revenue is recorded.”

 SEC Comment 8:  (Notes to Consolidated Financial Statements, page F-8, Note 1 – Significant Accounting
Policies, page F-8, Revenue Recognition, page F-11)

 In this regard, we noted on page 2 that you are both a manufacturer and reseller of
welding and cutting products. Please explain your related revenue recognition policies separately for those products that you manufacture and those that you resell and the impact on your accounting and presentation for revenues of reselling vs.
manufacturing transactions.

 Response 8: There is no difference in the revenue recognition policies for our manufactured versus
reseller products. The information provided in response 7 above applies to both manufactured and reseller products.

 SEC Comment
9:  (Note 3 – Segment Information, page F-17)

 We see that you present EBIT and EBIT, as adjusted for Special
Items as part of your table. Please tell us why you believe this presentation complies with the guidance in Item 10(e) of Regulation S-K and Question 102.09 of the Staff’s Non-GAAP Financial Measures Compliance and Disclosure
Interpretations dated January 15, 2010.

 Response 9: We believe that our disclosure of EBIT, as adjusted and EBIT in Note 3 of our
December 31, 2009 Form 10-K is in accordance with Accounting Standards Codification (“ASC”) 280, Segment Reporting. ASC 280-10-50-22 states that “A public entity shall report a measure of profit or loss and total assets for each
reportable segment.” ASC 280-10-50-30.b requires a reconciliation of “The total of the reportable segments’ measures of profit or loss to the public entity's consolidated income before income taxes, extraordinary items, and
discontinued operations.”

 Question 104.01 of the Staff’s Non-GAAP Financial Measures Compliance & Discussion
Interpretations, dated January 15, 2010, clarifies that “Non-GAAP financial measures do not include financial measures that are required to be disclosed by GAAP. Exchange Act Release No. 47226 lists “measures of profit or loss
and total assets for each segment required to be disclosed in accordance with GAAP” as examples of such measures.”

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 SEC Comment 10:  (Note 4 – Rationalization and Asset Impairments, page
F-21)

 We see your disclosure that the fair values of impaired long lived assets were determined primarily by third party appraisal.
Please tell us and revise future filings, including any amendments, to clarify the nature and extent of the third party appraiser’s involvement and management’s reliance on the work of the independent appraisers. Please refer to Question
141.02 of the Compliance and Disclosure Interpretations on Securities Act Sections, which can be found at http://www.sec.gov/divisions/corpfin/guidance/sasinterp.htm and which would be applicable to the extent your Form 10-K is incorporated
by reference into any registration statement.

 Response 10: We considered the values obtained from an independent appraiser in
determining the fair value of impaired long-lived assets. We, not the appraiser, are responsible for estimating fair value. As such, we will not refer to independent appraisals used in estimati