SecProbe.io

Mail Stop 3561

        July 24, 2008

Jeffrey S. Lorberbaum
Chairman, President, and Chief Executive Officer
Mohawk Industries, Inc.
P.O. Box 12069
160 S. Industrial Blvd.
Calhoun, GA 30701

Re: Mohawk Industries, Inc.
Form 10-K for Fiscal Year Ended December 31, 2007
Filed February 29, 2008
Definitive Proxy Statement on Schedule 14A
Filed April 7, 2008
File No. 001-13697

Dear Mr. Lorberbaum:

We have reviewed your response letter dated July 1, 2008 and have the following
additional 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 in
sufficient detail how you intend to comply by pr oviding us with your proposed revisions.
If you disagree, we will consider your e xplanation as to why our comments are
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
July 24, 2008 Page 2
Form 10-K for the Fiscal Year Ended December 31, 2007

Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 19

Liquidity and Capital Resources, page 23
1. We note your response to comment 3 in our letter dated June 3, 2008.  We understand from your response that the in crease in inventory from December 31,
2006 to December 31, 2007 was primarily driven by the acquisition of the Columbia wood flooring business in the third quarter of 2007, and that the
increase in inventory thus far in 2008 is  due to anticipated seasonal changes in
demand and is consistent with historical increases.  Please consider disclosing in
future filings information similar to that provided in your response to us, as we continue to believe that i nvestors benefit from insight into the underlying factors
behind your increasing inventory levels  at a time when your revenues are
declining.

Definitive Proxy on Schedule 14A

Compensation Discussion and Analysis, page 9
2. We note your response to comment 7 in our letter dated June 3, 2008 and we
reissue that comment.  Please provide us on a supplemental basis a detailed
analysis regarding how disclosure of each of the metrics would cause you competitive harm.  For example, you should explain how (1) disclosure of earnings per share for the company for a completed year and (2) each of the metrics could be “reverse engineered” to cause the company competitive harm.
3. We note your response to comment 8 in our letter dated June 3, 2008.  As
requested, please provide us the proposed disclosure based on the 2008 proxy statement.

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have  additional comments after reviewing your
response to our comments.

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
July 24, 2008 Page 3
You may contact Jennifer Thompson, Accounting Bran ch Chief, at (202) 551-
3737, if you have any questions regarding the financial statements and related matters.
Please contact Ronald E. Alper, Staff Attorney, at (202) 551-3329, Ellie Bavaria, Special Counsel, at (202) 551-3238, or me, at (202)  551-3720, with any other questions.

Sincerely,

       H. Christopher Owings
Assistant Director

cc:  R. David Patton, Esq.
       Via facsimile (404) 881-7777