SecProbe.io

Mail Stop 3561

December 18, 2017

John B. Cozzolino
Chief Financial Officer
Albany International Corp.
216 Airport Drive
Rochester, New Hampshire  03867

Re: Albany International Corp.
 Form 10-K for the Fis cal Year Ended December 31, 2016
Filed March 1, 2017
File No.  1-10026

Dear Mr. Cozzolino :

We have reviewed your filing an d have the following comment .  In our comment, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If  you do not believe our
comment applies  to your facts and circumstances , please tell us why in your response.

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

Form 10 -K for the Fiscal Year Ended December 31, 2016

Item 8. Financial Statements and Supplementary Data

17. Commitments and Contingencies

Asbestos Litigation, page 94

1. Please address the following comments related to your asbestos litigation:

 Please tell us when you accrue a loss for asbestos claims, both asserted and unasserted,
and how your accounting complies with ASC 450.  In doing so, tell us if you accrue for
claims in advance or only upon or when nearing settlement.  Also tell us the tot al amount
accrued at fiscal year -end 2016 for asbestos claims and provide a breakdown of the
accrual between asserted and unasserted claims.

John B. Cozzolino
Albany International Corp.
December 18, 2017
Page 2

  Explain to us your accounting policy for recording insurance recoveries associated with
asbestos claims.

 Tell us your accounting policy for legal costs expected to be incurred in connection with
your asbestos claims.

 We note your disclosure that you “do not believe a meaningful estimate can be made
regarding the range of possible loss with respect to pendi ng or future claims.”  Clarify if
this disclosure means that you are unable to estimate an amount to accrue under ASC
450-20-25-2 or if it means you are unable to estimate a range of reasonably possible loss
in excess of amounts accrued under ASC 420 -20-50-3 and -4.  In either case, considering
your extensive history dealing with asbestos claims, tell us why you are unable to
determine a meaningful loss estimate and why, per page 95, you “are unable to predict
the number and timing of such future claims.”  Please note that under the 420 -20-50-3
and -4 disclosure requirement s an estimate does not necessarily require confidence or
precision since an estimate is, by definition, imprecise.

 Based on the rollforwards of your claims activity on pages 94 and 95, it appears that there
are several long outstanding unresolved claims against you.  To the extent categorizable,
explain to us the nature of the remaining unresolved claims, including whether or not
these claims are materially different than the claims you have already settled.  For
example, clarify if your long outstanding claims generally involve more serious claims,
such as ones that are seeking materially higher damages.

We remind you that the company and its management are responsible for the accurac y
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Robert Babula, Staff Accountant at  (202) 551 -3339  or Andrew Blume,
Staff Accountant at (202) 551 -3254, if you have quest ions regarding  this comment  on the
financial statements and related matters.  Please contact me at (202) 551 -3737  with any other
questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief
Office of Consumer Products