SecProbe.io

Mail Stop 3561

        January 5, 2009

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
Form 10-Q for the Period Ended September 27, 2008
Filed November 12, 2008
File No. 001-13697

Dear Mr. Lorberbaum:

We have reviewed your response letter  dated November 20, 2008 and have the
following additional comments.  You should comply with the comment in all future
filings, as applicable.  Please confirm in writin g that you will do so and also explain to us
in sufficient detail how you intend to comply by providing us with your proposed revisions.

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
January 5, 2009 Page 2
Definitive Proxy on Schedule 14A

Compensation Discussion and Analysis, page 9
1. We note your response to comment one in  our letter dated November 5, 2008 and
continue to believe that you should disclose these metrics.  Please undertake to
provide this information in future filings.

Form 10-Q for the Period Ended September 27, 2008

Financial Statements for the Period Ended September 27, 2008

Note 5.  Intangible Assets and Goodwill, page 10
2. We note your discussion of the impairment of goodwill and other intangible assets during your third fiscal quarter and have the following comments:

• We note your description of the facts and circumstances leading to these
impairments; however, it is unclear to  us from your current disclosures
exactly how these facts and circumstances differed from those present earlier in your fiscal year.  Please expl ain to us in more detail, and ensure
that you clearly address in your upcom ing Form 10-K, the evolution of
facts and circumstances throughout 2008 such that an interim test of
goodwill for impairment as contemplated by paragraph 28 of SFAS 142 was appropriate in your th ird fiscal quarter but wa s not appropriate at any
earlier period.  Your response to us should specifically address in
reasonable detail how management considered whether any amounts of
impairment should have been recorded  in your first or second fiscal
quarters.
• Please tell us where management had previously disclosed that such
impairments were becoming more likely or had become reasonably likely.
If you did not previously disclose this to your readers, please help us to understand how your disclosures in previous Forms 10-Q for 2008 complied with the requirement in Item  303 of Regulation S-K to disclose
known trends or uncertainties that you reasonably expect to have a
material impact on your results.  We remind you that one of the primary objectives of Management’s Discussi on and Analysis is to provide your
readers with a view of the company through the eyes of management.  We
assume that management was aware of the declining conditions during
2008 that made an impairment loss increasingly likely.
• We note that the amount of impairme nt recorded in your third fiscal
quarter was estimated consistent with  paragraph 22 of SFAS 142.  Please
tell us whether you have completed the final measurement of the

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
January 5, 2009 Page 3
impairment loss as of September 27, 2008, and if so, please tell us whether
any change resulted to the estimated amount of impairment reported in your Form 10-Q.
• Also tell us whether you have co mpleted your annual impairment test,
performed during the fourth fiscal quarter, and if so, please tell us whether any additional impairment was recorded in the fourth fiscal quarter due to
changes in circumstances after September 27, 2008.
• Given the significant impairment reco rded during 2008, please ensure that
you fully consider the disclosure requirements of SOP 94-6, SAB 5:Y, and SFAS 142, along with the guidance in our Release No. 33-8350, available
at
http://www.sec.gov/rules/interp/33-8350.htm , to provide your readers
with insight into the likelihood of a dditional impairments resulting from
reasonably likely changes to your a ssumptions.  In this regard, you may
find it useful to provide a sensitivity analysis in your discussion of Critical Accounting Policies within Manageme nt’s Discussion and Analysis to
illustrate the impact of such reasonably likely changes.

******

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
responses to our comments.

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