SEC Comment Letter for MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968) (MHK) — Jun 7, 2010
MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968)
Date: June 7, 2010 · CIK: 0000851968 · Accession: 0000000000-10-031654
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-13697
Referenced dates: May 3, 2010
Letter
Re: Mohawk Industries, Inc. Definitive Proxy Statement on Schedule 14A Filed April 5, 2010 File No. 001-13697 Dear Mr. Lorberbaum: We have reviewed the letter of your counsel dated May 17, 2010 and have the following comments. Please feel free to call us at the telephone numbers listed at the end of this letter with any questions you may have.
Mail Stop 3561 June 7, 2010 Jeffrey S. Lorberbaum Chairman and Chief Executive Officer Mohawk Industries, Inc. 160 S. Industrial Blvd. Calhoun, Georgia
Definitive Proxy Statement on Schedule 14A
Nominees for Director, page 2 1. We reviewed your response to comment two in our letter dated May 3, 2010. Please confirm in writing that you provide the requested disclosure in future filings. Compensation Discussion and Analysis, page 12
Elements of our Compensation Program, page 14
Annual Incentives, page 14
2. We reviewed your response to comment three in our letter dated May 3, 2010. Please confirm that in future filings y ou will clarify whether and, if so, how you have adjusted consolidated operating income, or other metrics you may use in the future, and explain to us in sufficient deta il for an understanding of the disclosure how you intend to comply by providing us with your proposed revisions.
Jeffrey S. Lorberbaum Mohawk Industries, Inc. June 7, 2010 Page 2 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. Please contact Catherine Brown, Staff Atto rney, at (202) 551-3513 or me at (202) 551-3720 with any questions you may have.
Sincerely,
H. Christopher Owings Assistant Director
cc: R. David Patton, Esq. Alston & Bird LLP
Via Facsimile
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Mail Stop 3561 June 7, 2010 Jeffrey S. Lorberbaum Chairman and Chief Executive Officer Mohawk Industries, Inc. 160 S. Industrial Blvd. Calhoun, Georgia Re: Mohawk Industries, Inc. Definitive Proxy Statement on Schedule 14A Filed April 5, 2010 File No. 001-13697 Dear Mr. Lorberbaum: We have reviewed the letter of your counsel dated May 17, 2010 and have the following comments. Please feel free to call us at the telephone numbers listed at the end of this letter with any questions you may have. Definitive Proxy Statement on Schedule 14A Nominees for Director, page 2 1. We reviewed your response to comment two in our letter dated May 3, 2010. Please confirm in writing that you provide the requested disclosure in future filings. Compensation Discussion and Analysis, page 12 Elements of our Compensation Program, page 14 Annual Incentives, page 14 2. We reviewed your response to comment three in our letter dated May 3, 2010. Please confirm that in future filings y ou will clarify whether and, if so, how you have adjusted consolidated operating income, or other metrics you may use in the future, and explain to us in sufficient deta il for an understanding of the disclosure how you intend to comply by providing us with your proposed revisions. Jeffrey S. Lorberbaum Mohawk Industries, Inc. June 7, 2010 Page 2 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. Please contact Catherine Brown, Staff Atto rney, at (202) 551-3513 or me at (202) 551-3720 with any questions you may have. Sincerely, H. Christopher Owings Assistant Director cc: R. David Patton, Esq. Alston & Bird LLP Via Facsimile