SecProbe.io

Mail Stop 3561
 March 25, 2010
 Jeffrey S. Lorberbaum Chairman and Chief Executive Officer  Mohawk Industries, Inc.  160 S. Industrial Blvd. Calhoun, Georgia

Re:  Mohawk Industries, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009
Filed February 26, 2010 File No. 001-13697
 Dear Mr. Lorberbaum:
 We have reviewed your filing and have the following 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 for an understanding of the
disclosure how you intend to comply by providing us with your proposed revisions.  If
you disagree, we will consider your explanation as to why our comments are inapplicable
or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may raise additional
comments.               Please understand that the purpos e of our review process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filings.  We look forward to working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Form 10-K for the Fiscal Year Ended December 31, 2009

Item 1.  Business, page 3
 1. If material to the business of any of your segments, please revise to provide the
disclosure required by Item 101(c)(1)( vi) and (viii) of Regulation S-K.

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
March 25, 2010 Page 2   Item 7. Management’s Discussion and Analys is of Financial Condition and …, page 19

Overview, page 19
 2. In the fourth paragraph under this heading, please revise to describe in more detail
the identified “trend of inci dents related to the use of  new technology in certain
commercial tiles.”

Year Ended December 31, 2009, as Comp ared with Year Ended …, page 20

Net sales, page 20
 3. Please revise your net sales disclosure to describe in more de tail the “unfavorable
price and product mix” you experienced.  For example, please clarify whether
your decline in net sales resulted from pr ice decreases, the sale of lower priced
products, the sale of lower margin products and/or other factors.  Similarly, please
also describe in more detail the benefit “due to the net effect of price increases
and product mix” reflected in your comparison of 2008 and 2007 net sales
discussion.

Selling, general and administrative expenses, page 21

4. Please revise your disclosure under this he ading, or in another appropriate place,
to discuss in more detail the “various cost savings initiati ves implemented by the
Company” and the status of these initiativ es.  In this regard, we note for example
that your latest earnings release filed with your Fo rm 8-K on February 25, 2010
references the “implementation of cost sa vings efforts, perso nnel reductions and
plant consolidations” and notes that all of your “segments have reduced
infrastructure and capacity and improved productivity.”
 Critical Accounting Policies, page 28

 5. Please revise the discussion of your critic al accounting policies to focus on the
assumptions and uncertainties that underl ie your critical accounting estimates.
Please also quantify, where material, and provide an analysis of the impact of critical accounting estimates on your fina ncial position and results of operations
for the periods presented, including the effects of changes in critical accounting
estimates between periods.  In addi tion, please include a qualitative and
quantitative analysis of the sensitivity of reported re sults to changes in your
assumptions, judgments, and estimates, including the likelihood of obtaining
materially different results if differe nt reasonably likely assumptions were
applied.  For example, if reasonably like ly changes in an assumption used in
testing your goodwill or other long-lived asse ts for impairment or used in your

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
March 25, 2010 Page 3
valuation allowance on your deferred tax assets would have a material effect on your financial condition or results of operations, the impact that could result given the range of reasonably outcomes should be  disclosed and quantified.   Refer to
Section V of our Release No. 33-8350.

Notes to Consolidated Financial Statements, page 41

(5) Goodwill and Other Intangible Assets, page 48

6. We note that during 2008 the company reco rded a $1.5 billion impairment charge.
It appears that this charge  was recorded predominantly in the third quarter of 2008
as the result of an interim impairment test.  Please explain to us in more detail the
indicators that led you to perform this  interim impairment test for goodwill and
indefinite lived assets.  Please also explain to us whether you performed any
interim impairment testing prior to your ne xt annual required testing.  In addition,
please explain whether the significant declin e in your stock price that occurred in
the latter part of calendar 2008 and the first quarter of 2009 was indicative of any of the events identified in ASC 350-20-35-30.

(7) Long-term Debt, page 50

7. Please explain to us why you omitted disc losing any of the major terms of the
debt included in the category Industrial re venue bonds, capital leases and other.
 (9) Derivative Financial Instruments, page 53

 8. Please explain to us the purpose for which you enter into long-term supply
agreements for natural gas and your use of natural gas in your operations.  Please consider clarifying this matter to your readers in future filings to the extent material.
(12) Employee Benefit Plans, page 57

 9. We note the chart on page 59 that breaks  down your projected benefit obligation,
accumulated benefit obligation and fair va lue of plan assets into plans with
accumulated benefit obligation in excess of pl an assets and plans with plan assets
in excess of accumulated benefit obligati ons.  The projected benefit obligation
and fair value of plan assets do not app ear to reconcile to the total projected
benefit obligation and fair value of plan a ssets in the chart on page 58.  The totals
for projected benefit obligation and fair value of plan assets for plans with plan assets in excess of accumulated benefit ob ligations equal the totals shown on page
58.  Please advise us if this was in error.  If so, please supplementally provide us

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
March 25, 2010 Page 4
the correct amounts for each of the aff ected items.  We may have further
comment.

Item 15.  Exhibits and Financia l Statement Schedules, page 70

10. Please ensure that the material agreemen ts incorporated by reference to other
filings contain complete copies of th ese agreements, including all exhibits,
schedules and attachments. Refer to It em 601(b)(10) of Regulation S-K. For
example, we note that all of the exhibits and schedules were omitted from Exhibit 10.1 to your Current Report on Form 8-K filed September 2, 2009, which is a material agreement in your 10-K listed as Exhibit 10.4.  Please review your
material agreements, and re-file complete  agreements with your next current or
periodic report.

* * * * *

 Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  You may wish  to provide us with marked copies of your
disclosure to expedite our revi ew.  Please furnish a letter th at keys your responses to our
comments and provides any requested inform ation.  Detailed cover letters greatly
facilitate our review.  Please understand th at we may have additional comments after
reviewing your responses to our comments.              We urge all persons who ar e responsible for the accuracy and adequacy of the
disclosure in these filings to  be certain that the filings include all information required
under the Securities Exchange Act of 1934 and that they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

In connection with responding to our comments, please provide, in writing, a
statement from the company acknowledging that:
• the company is responsible for the adequacy and accuracy of the disclosure in the filings;

• staff comments or changes to disclosu re in response to staff comments do
not foreclose the Commission from ta king any action with respect to the
filings; and

• the company may not assert staff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.

Jeffrey S. Lorberbaum
Mohawk Industries, Inc.  March 25, 2010 Page 5
In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filings.
 You may contact Lisa Sellars, Staff Accountant, at (202) 551-3348 or Jim
Allegretto, Senior Assistant Chief Accountan t, at (202) 551-3849 if  you have questions
regarding comments on the fina ncial statements and relate d matters.  Please contact
Catherine Brown, Staff Attorney, at (202) 551-3513 or me at (202) 551-3720 with any
other questions you may have.

Sincerely,

H. Christopher Owings  Assistant Director