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Albany International Corp.

P.O. Box 1907

Albany, NY 12201

(455 Patroon
Creek Blvd., Suite 206, Albany, NY 12206)

Tel. 518 445-2281

Fax: 518 677-1097

E-mail: john.cozzolino@albint.com

John Cozzolino

Chief Financial
Officer & Treasurer

January 15, 2016

Ms. Jennifer Thompson

Accounting Branch Chief, Office of Consumer Products

Securities and Exchange Commission

Washington, D.C. 20549

 Re: Albany International Corp.

Form 10-K for the Year Ended December 31, 2014, filed
February 27, 2015

Form 10-Q for quarterly period ended September 30,
2015, filed October 28, 2015

File No. 1-10026

Dear Ms. Thompson:

We are pleased to respond to your letter dated December
22, 2015. For ease of review, we have set forth below the numbered comments from your letter and our responses thereto.

With respect to the response that involves a proposed
revision to the manner in which the related items were addressed in the filings in which they appeared, we have included in our
response an illustration of how the revised disclosure would have appeared in the relevant filing. New additions to the text are
underlined. Each illustration would also apply to any future filings in which the disclosure item is repeated.

Gross Profit, page 24

1. Tell us what consideration you gave to expanding your
gross profit discussion to provide more insight into cost of goods sold either here or within your Segment Results of Operations
beginning on page 30. In this regard, we note cost of goods sold is material to the Company and we assume could potentially vary
across your two segments. Refer to Item 303(a)(3)(i) of Regulation S-K.

Response: The form and content of our gross profit
discussion is influenced by the manner in which we assess the Company’s gross profit performance as compared to prior periods,
which is in turn influenced by our gross profit goals, for each segment and for the Company as a whole.

    1

In our Machine Clothing segment, as we have stated in
this and earlier reports, we consider the market as having flat growth potential, and our objective is to maintain approximately
the same level of profitability, despite factors such as competition and inflation. Within this segment, we therefore assess performance
based on the extent to which we have succeeded in maintaining gross profit (as well as net sales and operating income) compared
to prior periods. Changes in currency translation rates and specific items such as restructuring charges or unusual gains or losses
affect comparability, so we always include analysis of those effects. To the extent that other items cause a significant variance
in gross profit, net sales or operating income, we endeavor to identify and quantify those that had the most significant impact
compared to the prior period. Based on our communications with investors and analysts, we are of the view that they assess Machine
Clothing performance in the same manner.

By way of illustration, Machine Clothing gross profit
declined $6.8 million from 2013 to 2014, and the net effect of the items that we identified on pages 24 and 30 explain a net decrease
of $8.4 million. Our analysis of gross profit changes in support of this discussion did not identify any other individual items
with an impact that exceeded $1 million.

Likewise, in our disclosures for Engineered Composites
segment results, we note that $5.0 million of the $6.0 million gross profit increase was attributed to improved performance in
our Boerne, Texas facility.

While we therefore consider our gross profit discussion
to meet the requirements of Item 303(a)(3)(i) of Regulation S-K, in light of your comment, we have considered the extent to which
the discussion as it relates to the Machine Clothing segment could be improved, and greater clarity provided about which of the
discussed items affected sales, costs of goods sold, or both. We have also proposed modifications to our Engineered Composites
segment results disclosure to provide more detail regarding this improved performance.

See below the revisions to 2014 Form 10-K, pages 24, 30
and 32, that we propose to include in our Annual Report on Form 10-K for the year ended December 31, 2015. We would also expect
to include similar detail in future filings with respect to future periods:

Total Company – page 24

The following table summarizes gross profit by business
segment:

The increase in gross profit during
2014 was principally due to the net effect of the following:

    2

 · An improvement in gross profit margin in the AEC segment from
5.8 percent to 11.9 percent, principally due to improvements in profitability at AEC’s Boerne, Texas operation.

 · The reduction in MC net sales described above resulted in
a gross profit decrease of $8.5 million in the MC segment due to lower sales.

 · MC gross profit margin improvement, principally due to the
effect of restructuring in France and productivity improvement.

 · A $1.7 million decrease in Cost of goods sold principally
due to cost savings from restructuring activities, partially offset by inflation on wages and other manufacturing costs. Increase

 · A $1.6 million charge to Cost of goods sold of
$1.6 million in 2014 to correct an error in the value of Machine Clothing inventories reported in prior periods.

 · AEC’s Boerne, Texas operation increased gross profit by $5.0
million, principally due to operational improvements that resulted in lower cost of goods sold.

 · A $1.9 million reduction in cost associated with the Company’s
U.S. postretirement plan, principally resulting from plan changes in 2013. These costs are reported as Corporate expenses in
the table above.

MC Gross Profit – Page 30

Gross Profit

The decrease in 2014 gross profit
was principally due to the net effect of the following:

 · An $8.5 million decrease due related to lower
sales, as noted above.

 · A $1.7 million decrease in Cost of goods sold principally due to
cost savings from restructuring activities, partially offset by inflation on wages and other manufacturing costs. increase
due to improved gross margin, offset by

 · A $1.6 million charge for the correction of the inventory valuation
error during 2014. The improvement in gross profit percentage in 2014 was principally due to cost savings from restructuring
activities, partially offset by inflation on wages and other manufacturing costs.

AEC Gross Profit, page 32

2014 vs. 2013

    3

 · Higher gross profit margin due to improvements in profitability
at AEC’s Boerne, Texas operation increased gross profit by $5.0 million, principally due to operational improvements
that resulted in lower Cost of goods sold.

Report of Independent Registered Public Accounting
Firm, page 47

2. We note your predecessor independent accountant dual
dated their audit report for the effects of the revisions discussed in Notes 5, 8 and 11 to the consolidated financial statements.
Please explain to us whether this indicates the accountant reached a different conclusion from you about the materiality of these
errors. We note your disclosure in Notes 5, 8, and 11 that these errors were immaterial to your previously filed financial reports.

Response: Each of the error corrections in Notes
5, 8 and 11 to the consolidated financial statements resulted in a revision to amounts that had been previously reported on by
the predecessor independent accountant.  The audit work performed by the predecessor independent accountant in connection
with these revisions required them to dual date their audit report.  The predecessor independent accountant agreed with management
that the errors were immaterial to the previously filed financial statements.

Item 9A. Controls and Procedures, page 97

3. Please tell us what impact the errors disclosed in
Notes 5, 8 and 11 had on your conclusions regarding the effectiveness of your disclosure controls and procedures and internal control
over financial reporting. In your response, please address both how you reassessed your previously disclosed conclusions for prior
periods and how you were able to conclude that any control deficiencies had been remediated to reach a conclusion that disclosure
controls and procedures and internal control over financial reporting were effective as of December 31, 2014.

Response: We assessed the effectiveness of our
disclosure controls and internal controls over financial reporting (ICOFR) at both Q4 2014 when the control deficiencies were discovered
and we reconsidered our ICOFR assessment as of December 31, 2014, and as of the end of the relevant prior periods for which we
disclosed conclusions regarding the effectiveness of our controls.

We assessed the severity of the control deficiency taking
into account the following six step process which takes into account the guidance provided in the SEC’s 2007 Interpretive
Release, Commission Guidance Regarding Management’s Report on Internal Control Over Financial Reporting Under Section 13(a)
or 15(d) of the Securities Exchange Act of 1934:

 1. Determining whether a deficiency exists

 2. Identify the control that is deficient

 3. Determine whether the control deficiency is indicative of other deficiencies

 4. Evaluate the severity of the deficiency by considering magnitude and
likelihood of the potential misstatement

 5. Identify relevant compensating controls and conclude on the severity

 6. Aggregate similar deficiencies and evaluate the aggregated deficiencies
for severity

    4

In addition, prior to filing the 2014 Form 10-K, our process
included a review and discussion of the salient aspects and management considerations of the these matters with both our predecessor
and successor audit firms, as well as with the Audit Committee of our Board of Directors.

Set forth below are a summary of the considerations for
each of the revisions, and our conclusions regarding the effectiveness of our disclosure controls and procedures and internal control
over financial reporting.

Pension Footnote Error (Note 5)

ASC 820-10 requires that we categorize financial instruments,
including pension plan investments disclosed in our pension footnote, in accordance with the fair-value hierarchy specified in
the accounting standards. As part of our preparation of the footnote for the year ended December 31, 2014, it was determined that,
in previous years, we had misclassified the fair-value level of certain investments. This footnote presentation error related to
the misclassification of certain Level 2 pension investments as Level 1 assets, as well as the reporting of certain pooled investment
fund assets as debt securities rather than equity funds. The type and level of these investments had been determined some time
ago, in consultation with various investment managers and our actuarial consultant, and had not been reviewed since that time.
Our control is designed to evaluate the hierarchy classifications when we initially enter into an investment, and an annual reassessment
is not required unless there is a change in the investment composition. As such we had a deficiency in the design of our control.

When we assessed the magnitude of a possible error as
a result of the control deficiency, we considered whether the deficiency could have ever permitted an error that would be considered
material to users of the financial statements. As part of this consideration, we noted that the error was one that does not, and
never would, impact earnings, financial position or cash flows, nor have any effect on compliance with loan or other agreements,
or other compliance requirements. In our communications with investors, we do not recall having received any questions or comments
relating to our disclosures related to pension assets. Nor would an error of this nature, regardless of amount, have any impact
on management compensation.

We concluded that it was unlikely, therefore, that a footnote
presentation error of this type, regardless of the amount of assets incorrectly described or classified, or the amount of reclassification
needed to correct it, would ever be considered material by users of the financial statements. We further reasoned that this categorization
exercise is a discrete one within our financial reporting process, and is not related to any other controls nor indicative that
similar deficiencies are likely to exist.

Accordingly, we concluded that the deficiency, while significant,
did not constitute a material weakness and did not affect our conclusions about the effectiveness of controls in previous periods.
Our remediation procedures included a thorough review of new and previously existing investments to ensure proper classification.
We considered the control remediated as of December 31, 2014.

Deferred Tax Assets and Liabilities (Note 8)

    5

During the preparation of our 2014 income tax footnote,
we identified an error in our historical balance sheet presentation of deferred taxes and liabilities, due to the failure to apply
jurisdictional netting as required by ASC 740-10-45-6. While the gross values of deferred tax assets and liabilities were calculated
correctly, the final step of netting the deferred tax assets and liabilities by jurisdiction was missed.

To assist in the preparation of financial statements and
footnotes, we use a financial statement disclosure checklist which included an item for ASC 740-10-45-6. Our control documentation
requires that the financial disclosure checklist items be reviewed by both a preparer and reviewer with requisite knowledge. In
this case, the previous preparer of the tax section of the checklist did not ensure that the netting requirement included in the
tax section of the checklist had been correctly applied. Additionally, the tax section of the checklist was not reviewed by a second
person.

As a result, the operating effectiveness of this control
failed, and we determined that this was a significant control deficiency, but not a material weakness based on the following analysis.

Since the issue affected only the balance sheet and the
only impact of the correction was to net down assets and liabilities by an equal amount, with no impact to shareholders’
equity, we concluded that an appropriate metric for assessing impact was to consider the magnitude of the error as a percentage
of total assets. Applying this reasoning, we determined that the magnitude of the error was less than 5% in each year from 2010
– 2013. We also considered whether the deficiency could ever have resulted in an error of material amount. Since deferred
taxes are a function of timing differences on other assets and liabilities to which a tax rate is applied, it is highly unlikely
that the overstatement of assets and liabilities could have ever reached a significant percentage of total assets. In reviewing
the overstatements, we further noted that the amounts were relatively constant over the last five years, and that there were no
major tax strategies or initiatives during that period which would have caused a significant change in the composition of deferred
taxes.

We do not have, nor did we during this period have, any
bank covenants or compliance requirements based on current/non-current balance sheet classification, or working capital ratios
or levels. In our communications with investors, the balance sheet data that they closely monitor is net debt, capital expenditures,
and trends in accounts receivable or inventories. None of these were impacted by, nor could they be impacted by, this deficiency.

Moreover, we noted that the materiality of any financial
reporting error that involves an overstatement of any asset that is completely offset, in each asset line item in which it is reflected,
by an equally overstated liability should be substantially discounted. The manner in which the error arose – relating as
it did to a failure to net an asset by a corresponding liability – ensures that this will always be the case, and further
ensures