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Mail Stop 3561         May 5, 2008  Michael C. Nahl Executive Vice President  and Chief Financial Officer Albany International Corp.  1373 Broadway Albany, NY 12204
 Re: Albany International Corp.
  Form 10-K for Fiscal Year Ended December 31, 2007
Filed February 29, 2008
  Definitive Proxy Statement on Schedule 14A
  Filed March 26, 2008
File No. 1-10026
 Dear Mr. Nahl:
 We have reviewed your filings and ha ve the following comments.  You should
comply with the comments in all future filings, as applicable.  Please confirm in writing
that you will do so, and also explain to us how you intend to comply.  If you disagree, we
will consider your explanation as to why our comments are inapplicable or a revision is
unnecessary.  Please be as detaile d as necessary in your explan ation.  After reviewing this
information, we may raise additional comments.
  Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Annual Report on Form 10-K for Fiscal Year Ended December 31, 2007

 Cover Page

1. Please replace the SEC file number you ha ve identified on th e Form 10-K with
the file number indicated above.

Michael C. Nahl
Albany International Corp.
May 5, 2008 Page 2  Employees, page 22

2. Please disclose whether any of your employees are union members that are
subject to collective ba rgaining agreements.
 Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 36

3. Throughout your document, you disclose that  you have initiated a deliberate,
intensive three-year proc ess of restructuring and performance improvement
initiatives.  Please expand your disclo sure to describe your performance
improvement initiatives, including the specific actions you have taken and will
take to implement your plans.  We note your discussion of the outlook of this plan
on page 49; however, due to the significan ce of this plan, we believe this should
be highlighted in the overview section of MD&A since it provides context for the
remainder of your MD&A discussion.

Furthermore, please discuss the types of  expenses included as part of your
performance improvement in itiatives, including the line item(s) these expenses
are classified on your statement of oper ations and the reasons why they are
classified as such.  Please quantify the impact of these expenses when describing the changes in segmental gross margin and segmental selling, general, technical
and research expense, since a significant portion of the increase in these line items
relates to expense fo r performance improvement initiatives.

Review of Operations, page 38

2007 vs. 2006, page 38
 4. We note that you have quantified the impact of changes in currency translation
rates on consolidated and segmental net sales and on consolidated STG&R
expenses.  Please tell us how you consider ed quantifying the impact of changes in
currency translation rates on consolidated gros s profit.  Also tell us, and clarify to
your readers, whether the impact of changes in currency translation rates on gross profit and STG&R expenses is allocated to  your segments.  If so, please address
these items in your analysis of segmental gross profit and segmental operating income.

5. To the extent material to understand ing your results of operations, please
separately discuss the changes in th e “selling and general expenses” and
“technical, product engineering, and research  expenses” line items as presented on
your income statement.  Also, please cons ider discussing the changes in research
expense and unallocated expenses disclo sed on page 40 as a subset to your
discussion of consolidated STG&R expe nses, as your curren t presentation of

Michael C. Nahl
Albany International Corp.
May 5, 2008 Page 3
these segmental reconciling items di rectly beneath your discussion of
consolidated operating income, which includes these segmental reconciling items, may be confusing to your readers.
 6. We note your discussion of income tax e xpense in the middle of page 40.  Please
tell us and better explain to your read ers why your effective income tax rate
appears unusually low for 2007.  In this re gard, we note your reconciliation of the
effective tax rate on page 76, but it is unclear from your current disclosures why many of these line items are significantly different from the previous two years.

Paper Machine Clothing Segment, page 40

 7. We note that net sales and operating in come for 2006 were reduced due to a
change in contract terms with a major customer.  Please elaborate on the circumstances of this contract change, including how and why this impacted your
revenue and expense recognition.

Albany Door Systems Segment, page 41

 8. Please discuss in more detail the underlying reasons for the increased sales of new products and the aftermarket business in Eu rope, and quantify the impact of each
contributing factor if possible.  Additiona lly, please quantify the impact of the
R-Bac acquisition on net sales, and tell us  how you considered disclosing this
acquisition’s impact on gross profit and operating income.  If this acquisition did  not have a significant impact on your results,  please clarify this matter to your
readers.

Liquidity and Capital Resources, page 43

 9. We note that your increase in cap ital expenditures in 2007 and 2006 were
principally due to the PMC strategic investment program announced in January 2006.  Please elaborate on the fundamentals of  this plan and how this has and will
affect your operations.

Critical Accounting Policies and Assumptions, page 48

 10. We note that some of your critical accounting policies simply repeat the
information contained in Note 1 to your financial statements.  We remind you that
such disclosure should supplement, not duplicate, the description of accounting
policies that are already disclosed in th e notes to the financial statements. The
disclosure should provide gr eater insight into  the quality and variability of
information regarding financial conditi on and operating performance. While
accounting policy notes in the financial statements generally describe the method used to apply an accounting principle, the discussion in MD&A should present a

Michael C. Nahl
Albany International Corp.
May 5, 2008 Page 4
company's analysis of the un certainties involved in applying a principle at a given
time or the variability that is reasonably likely to result from its application over
time.  You should also quantify the sensitivity of your estimates to change, based on other outcomes that are reasonably likel y to occur and would have a material
effect on your financial statements. Re fer to Section V of our Release
No. 33-8350, available on our website at www.sec.gov/rules/interp/33-8350.htm
.
Please revise as appropriate, and show  us what any revisions will look like.

Financial Statements, page 53
 Notes to Consolidated Financial Statements, page 59

 1.  Accounting Policies – Revenue Recognition, page 59

11. We note your revenue recognition polic y and have the following comments:

• We read that certain contracts in the Applied Technologies segment are accounted
for using the percentage of completion me thod.  Please describe to us in more
detail any contracts that you account fo r using the percentage of completion
method, and tell us how you determined th ese contracts qualifi ed for percentage
of completion accounting under SOP 81-1.
 • We read that the timing of revenue rec ognition is dependent upon the contractual
arrangement, and these arrangements are specific to each customer.  Please
explain to us in more detail the various types of contractual arrangements that you
offer to your customers and how you account for these arrangements, including
any types of arrangements that result in the recognition of revenue and transfer of title at any point other than delivery of the completed product.  Please expand
your accounting policy to more clearly indi cate the various types of contractual
arrangements to which you are referring, as  this may be unclear to your readers.

• We read on page 22 under Competition that you provide diverse services to your
customers, including consulting and storing fabrics for delivery to the user.  We
also read that you offer aftermarket serv ice and support for your door systems.
Please explain to us in more detail the various types of serv ices that you offer
your customers and how you account for thes e services, including at what point
you recognize revenue for any fabrics that you store for delivery to the user.  Tell
us how you determined you did not need to disclose your accounting policies for
these services in Note 1.  Also tell  us how you considered the guidance in
Rule 5-03 of Regulation S-X for separately disclosing net sales and cost of sales
for products and for services.

Michael C. Nahl
Albany International Corp.
May 5, 2008 Page 5

6.  Financial Instruments, page 68

 12. We note your discussion of the $180 m illion 2.25% convertible notes and the
related convertible note he dge and warrant transactions.  We have the following
comments:

• Please disclose to your readers a more de tailed explanation of  the circumstances
under which the convertible debt may be redeemed for cash, converted into Class
A stock, or converted into a combination of cash and stock.  Also clarify whether
these redemptions or conversions occur at  the option of the ho lder or at your
option.  Please show us what this en hanced disclosure will look like.

• With regards to the converti ble note hedge, please expl ain to us, and clarify to
your readers, whether you may acquire shar es that fully offset the delivery of
newly issued shares upon conversion of the notes.  In this regard, it appears from
the definition of Exercisable Options in your convertible note hedge transaction
confirmation agreement that you may only receive 40% of the shares you would issue upon conversion of the notes.

• With regards to the warrant transacti on, please tell us where you disclosed the
terms of the warrants as indicated by Rule 4-08(i) of Regulation S-X.
 • We read that you concluded that the convertible feature of the notes, the
convertible note hedge, and the warrant tr ansactions each meet the requirements
of EITF 00-19 to be accounted for as equity  instruments.  Please explain to us in
more detail how you reached these conc lusions, including whether all of these
agreements may be settled in unregistere d shares, and whether such a settlement
alternative triggers any penalties.
 • We note your registration rights agreemen t related to the convertible notes and
underlying shares.  Please provide us with your analysis of whether this
agreement contains a registration pa yment arrangement as defined by
FSP-EITF-00-19-2, and if so, please tell us how you considered the accounting
and disclosure guidance in FSP-EITF-00-19-2.

7.  Commitments and Contingencies, page 70

13. We note your discussion of lawsuits alleging that certain in dividuals suffered
personal injury as a result of exposur e to asbestos and have the following
comments:

• It appears that about two-th irds of the claims pending against you are in federal
court at the multidistrict litigation pa nel in Mississippi, and we note your

Michael C. Nahl
Albany International Corp.
May 5, 2008 Page 6
disclosures concerning these claims.  Howeve r, it is unclear to us that you have
provided all disclosures required by SF AS 5, SOP 94-6 and SAB Topic 5:Y for
the remaining one-third of the claims pending against you that are not at the
MDL.  Please advise, and if appropriate, re vise your disclosure to address more
clearly these claims.

• We note your disclosure at the top of page 71 of the total number of claims
outstanding at various dates.   Please refer to Question 3 of SAB Topic 5:Y and
provide us with a rollforward of the numb er of claims at each balance sheet date,
including the number of claims filed for each period presented and the number of
claims dismissed, settled or otherwise re solved for each period.  Additionally, if
the average settlement amount varies from y ear to year or reflects trends such as
increasing over time, it appears that additional disclosure on this matter may be
necessary.  Please also provide us with this information for Brandon.

• Please tell us whether you have any liabi lity for the facilities that produced the
asbestos-containing products .  If so, please tell us how you determined you did
not need to provide additional disc losures under SFAS 5, SOP 96-1 or SFAS 143,
if applicable.
 • Please disclose the above information to your  readers, either he re or in another
appropriate place in your filing, or tell us why such disclosures are not applicable.

12.  Reportable Segments and Geographic Data, page 78

14. We read at the top of page 79 that y ou do not allocate corporate headquarters
expenses to your segments, and we not e your presentation of these unallocated
expenses within your reconciliation to c onsolidated income before income taxes
on page 80.  Please provide your readers with  a brief descripti on of the types of
expenses that comprise your corporat e headquarters expenses.  Additionally,
please provide your readers with a brief desc ription of the types of assets that are
not allocated to your segments, particularly  the other assets presented within your
reconciliation to consolid ated total assets on page 81.  We believe this
information provides your readers with be tter insight into how management views
the company.  Refer to paragra phs 31(b) and (c) of SFAS 131.

15.  Stock Option and In centive Plans, page 88

15. We note your 2005 incentive plan that pr ovides key members of management
with incentive compensation based on achievement of certain performance targets
and are paid out over three years, partly in cash and partly in Class A common
stock.  We further note that you are rec ognizing expenses associated with this
plan over the vesting period, which incl udes the year for which performance
targets are measured and the two subse quent years.  Please tell us why you

Michael C. Nahl
Albany International Corp.
May 5, 2008 Page 7
recognize expense for this plan over a vesting period that includes the two
subsequent years, and explain to us in  more detail how this complies with
SFAS 123(R).  Also tell us whether you classi fy these awards as liabilities or as
equity, and the accounting guidance y ou are relying on in reaching your
conclusion.
 Disclosure Controls and Procedures, page 95

16. You state that your certifyi ng officers concluded that you r disclosure controls and
procedures were effective in “ensuring that information required to be disclosed in the periodic repo rts that [you] file[]  or submit[] under the Exchange Act is
accumulated and communicated to [your] management, including [your] Chief Executive Officer and Chief Financial Offi cer, as appropriate to allow timely
decisions regarding required disclosure.”  In future filings, please revise your
conclusion to include the full definition of disclosure controls and procedures as
outlined in Exchange Act Rule 13a-15(e) rather than the summarized definition you include now.  In this regard, please st ate, if true, whether the same officers
concluded the controls and procedures were  effective to “ensure that information
required to be disclosed by [you] in the re ports that [you] file or submit under the
Act is recorded, processed, summarized and reported, within the time periods
specified in the Commission’s rules and fo rms” and to “ensure that information
required to be disclosed by [you] in the re ports that [you] f