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Mail Stop 3561         October 14, 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 letter dated May 30, 2008 and have the following
comments.   Please 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

Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 36

Review of Operations, page 38

2007 vs. 2006, page 38

1. We have reviewed your response to comm ent 7 in our letter dated May 5, 2008.
Since you finalized the contract negotia tions during 2006, and the contract was
retroactive to January 1, 2006, it is unclear to us why th e change in timing of
transfer of title would aff ect the change in your net sa les for PMC for 2007 versus
2006, since we assume that, including  your reversal of revenue in 2006
immediately following finalization of the new contract, revenues were recognized
in the same manner for both annual peri ods.  Instead, given the January 1, 2006

Michael C. Nahl
Albany International Corp.
October 14, 2008 Page 2
 effective date of this change, this woul d appear to solely impact your comparison
of 2005 versus 2006.  Either further explain why the change in contract terms is
used to explain fluctuations from 2006 to 2007, or advise us if our understanding
or assumptions are incorrect.  To the extent applicable in future filings, you should also better explain this matter to your readers.
 Liquidity and Capital Resources, page 43

2. We have reviewed your response to comm ent 9 in our letter dated May 5, 2008.
We note your discussion of the PMC strategic investment program in the sixth risk factor and note your discussion of your deliberate, intensive three-year
process of restructuring and performance improvement initiatives in MD&A Trends and MD&A Outlook.  If your strategi c investment program is part of your
performance improvement in itiatives, please clarify th at in MD&A. Additionally,
absent disclosure of the specific com ponents of the PMC strategic investment
program that caused increased capital expenditures, please provide a cross
reference to the sixth risk factor in your discussion of  capital expenditures so that
a reader will be aware that the increase was due to the construction of a new paper
machine clothing manufacturing facility in China, additional forming fabric capacity in Korea and Brazil, and add itional dryer fabric capacity in the
Company’s existing plant in Panyu, China.

Critical Accounting Policies and Assumptions, page 48

3. We have reviewed your response to co mment 10 in our letter dated May 5, 2008
and reissue the comment.  We reiterate that the purpose of critical accounting
polices is to provide insight into the va riability of manageme nt’s estimates for
accounting polices that you cons ider critical.  In doing so, you should discuss the
uncertainties in your estimates and, if  you believe that other outcomes are
reasonably likely to occur and may materi ally affect your financial statements,
you should quantify the sensitivity of your estimates to these reasonably likely
changes.  We believe that information w ould be beneficial to  an investor in
gaining insight to the potent ial effect on your financial statements given a change
in a significant estimate.

Furthermore, we note in your response to  comment 11 that you execute long term
contracts that are accounted under the percentage of completion method.  Given
the estimates involved in applying SO P 81-1, please consider discussing your
percentage of completion contracts and the basis for your appropriate experience in the estimation of total costs to be incurred in the execution of the contract as part of your discussion of critical accounting policies.

Michael C. Nahl
Albany International Corp.
October 14, 2008 Page 3  Financial Statements, page 53

 Notes to Consolidated Financial Statements, page 59

 1.  Accounting Policies – Revenue Recognition, page 59

4. We have reviewed your response to comm ent 11 in our letter dated May 5, 2008.
Given your vast offerings of products and services in ea ch segment as well as the
varying contractual terms resulting in di fferent revenue recognition policies, we
believe your revenue recognition policy should be more robust and informative.  As indicated in Question 1 to SAB Topi c 13:B, since you have different policies
for different types of revenue transactions , we believe the policy for each material
type of transaction should be disclosed.  Based on your response, it appears that in
addition to recognizing revenue at the tim e of delivery as is addressed in your
current policy, in certain cases title is tr ansferred and revenue is recognized when
products are consumed by the customer or  on a specified date regardless of when
delivery occurs.  Either revise your policy to  address these types of transactions or
demonstrate to us that the revenue genera ted by these transactions was immaterial
for each year included in your financial statements.  Additionally, notwithstanding your proposed revision to state within the description of your business that
revenues earned from services are insignifi cant, we believe that the best practice
is to briefly address your revenue recogn ition policy for serv ices within your
revenue recognition accounting policy footnot e to provide all relevant revenue
recognition information to your r eaders in one co ncise location.

5. Please refer to the third bullet point of  comment 11 in our letter dated May 5,
2008.  As previously requested, please expl ain to us at what point you recognize
revenue for any fabrics that you store fo r delivery to users, and if you recognize
revenue prior to delivery of these fabrics, explain to us in detail how you determined your methodology was appropriate under SAB Topic 13.
 12.  Reportable Segments and Geographic Data, page 78

6. We have reviewed your response to co mment 14 in our letter dated May 5, 2008,
including your proposed revi sion to your current disclo sures.  As previously
requested, please briefly disclose the type s of assets you include in the “other”
unallocated assets line item ( $86,507 at December 31, 2007) in your
reconciliation on page 81 as we believe this  information is useful to your readers
in understanding how management view s and evaluates your segments.

Michael C. Nahl
Albany International Corp.
October 14, 2008 Page 4  Form 10-Q for the Quarter Ended June 30, 2008

 Financial Statements for the Period Ended June 30, 2008

 Note 6. Discontinued Operations, page 10

7. Please confirm to us that in future fili ngs you will provide a ll of the disclosures
required by paragraph 47 of SFAS 144, including but not limited to the major classes of assets and liabili ties classified as discontinued operations on the face of
your balance sheet and the amounts of revenue and pretax profit or loss reported as “income from operations of discontinued business” on the face of your income statement.  Additionally, pl ease ensure that your MD&A analysis of results at
least briefly explains the changes in income from operations of discontinued
business and the changes in the relate d income tax expense when comparing
current results to prior periods.
 Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 28
 Review of Operations, page 31

8. Please consider revising your tabular pres entation of prior period restructuring
and performance-improvement initiatives expense to separately disclose expense related to restructuring and expens e related to performance-improvement
initiatives, similar to your disclosure fo r the current period, as we believe this
provides valuable information to your readers about one of the primary factors underlying the changes in your results.  In this regard, after locating this breakout
in your June 30, 2007 Form 10-Q, we unde rstand that the net increase of $5.5
million for the quarter is comprised of a decrease in restructuring expense of $5.4 million, offset by an increase in idle capaci ty costs of $1.7 million and an increase
in performance-improvement initiatives of  $9.1 million, but this is not apparent
from your current disclosures.  Simi larly, after reviewi ng your June 30, 2007
Form 10-Q, we understand that the net increase of $9.6 million for the six month period is comprised of a decrease in re structuring expense of $7.6 million, offset
by an increase in idle capacity co sts of $2.4 million and an increase in
performance-improvement initiatives of  $14.8 million, but this is not apparent
from your current disclosures.  We belie ve that investors greatly benefit from
understanding that your restructuring a nd performance-improvement initiatives
expenses are behaving in opposite manners and their fluctuations are offsetting each other, and we believe that this ta bular disclosure, along with your current
narrative disclosures, would make thes e fluctuations more easily understood.

9. We note your analysis of the effective income tax rate and your response to
comment 6 from our letter dated May 5, 2008.  We have the following comments:

Michael C. Nahl
Albany International Corp.
October 14, 2008 Page 5
• We continue to have concerns that your disclosures do not explain to your
readers why your effective tax rate has such significant fluctuations from year to year.  As indicated in our prior comment, you appear to have had
an unusually low effective tax rate in 2007, and we note that for the six
month period you had an effective tax rate for continuing operations of approximately 6% in 2007 as compared to 58% in 2008.  The disclosures in your Form 10-Q imply that this diffe rence is due to “discrete tax items,”
but we believe this explanation is overly broad since you have not
identified the specific tax items that  differed, nor have  you explained why
these items would differ by such a larg e amount from year to year.  Please
revise your MD&A analysis of results in future filings to explain in more
detail why your tax rate fl uctuated so significantly.

• We note that your Form 10-Q discusse s your effective tax rate before
discrete tax items, which is a non-GAAP measure.  It is unclear to us how
your presentation of this measure comp lies with Item 10(e) of Regulation
S-K or our guidance in our Frequen tly Asked Questions Regarding the
Use of Non-GAAP Financial Measures  (our Non-GAAP FAQ), available
at www.sec.gov/divisions/co rpfin/faqs/nongaapfaq.htm
.  If you wish to
present this measure in future filings, please show us how you will modify your disclosure to comply with this non-GAAP guidance.

10. We note your disclosure of per share m easures throughout your MD&A analysis.
Refer to our Non-GAAP FAQ and provide the disclosures required by Question
11 for each non-GAAP per share measure pr esented.  Please provide similar
disclosure in your Form  8-K filed August 8, 2008.

Definitive Proxy Statement on Schedule 14A

Benchmarking and Use of Consultant, page 22

11. We note your response to comment 18 of our letter dated May 5, 2008.  We
continue to believe with respect to the Mercer Executive Compensation Survey
and the Private Executive Compensation Surv ey that if the participants whose
data was used were identified to your compensation committee to determine the compensation of your named executive o fficers, then you must identify those
companies in your disclosure, regardless of  the contractual restrictions in Watson
Wyatt’s agreements.

* * *

Michael C. Nahl
Albany International Corp. October 14, 2008 Page 6   You may contact Yong Kim,  Staff Accountant, at (202) 551-3323 or in her
absence Jennifer Thompson, Accounting Bran ch Chief, at (202) 551-3737 if you have
questions regarding comments on the financial statements and related matters.  Please
contact Alexandra M. Ledbetter, Staff Atto rney, at (202) 551-3317 or Ellie Bavaria,
Special Counsel, at (202) 551-3238 or me at (202) 551-3720 with any other questions.
Sincerely,
    H. Christopher Owings
Assistant Director