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SEC Comment Letter for MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968) (MHK) — Oct 31, 2012

MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968)
Date: Oct. 31, 2012 · CIK: 0000851968 · Accession: 0000000000-12-059773

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: September 17, 2012

Date
December 31, 2011
Author
/s/ Jennifer Thompson
Form
UPLOAD
Company
MOHAWK INDUSTRIES INC (MHK) (CIK 0000851968)

Letter

October 31 , 2012 Via E -mail Mr. Jeffrey S. Lorberbaum Chief Executive Officer Mohawk Industries, Inc. 160 S. Industrial Blvd. Calhoun, Georgia 30701

Re: Mohawk Industries, Inc. Form 10-K for Fiscal Year Ended December 31, 2011 Filed February 29, 2012 File No. 001 -13697

Dear Mr. Lorberbaum :

We have reviewed your response dated October 1, 2012 and have the following additional comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response . If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

Financial Statements, page 36

Note (14) Commitments and Contingencies, page 65

1. Based on the information included in your response to comment 1 in our letter dated September 17, 2012 , it appears that you may have reasonably possible or probable losses in excess of amounts presently accrued. In future filings, please disclose the amount or range of reasonably possible losses in excess of the amounts accrued or provide a statement that such an estimate cannot be made as required by ASC 450 -20-50-3 through 50-4. Alternatively you may disclose, if true, that any such amounts in excess of the amounts accrued are not material in relation to your financial statements.

Mr. Jeffrey S. Lorberbaum Mohawk Industries, Inc. October 31, 2012 Page 2

You may contact Sondra Snyd er, Staff accountant , at (202) 551 -3332 or Jason Niethamer, Assistant Chief Accountant , at (202) 551 -3855 if you have questions regarding our comments . You may contact me at (202) 551 -3737 with any other questions.

Sincerely,
/s/ Jennifer Thompson

Show Raw Text
October 31 , 2012

Via E -mail
Mr. Jeffrey S. Lorberbaum
Chief Executive Officer
Mohawk Industries, Inc.
160 S. Industrial Blvd.
Calhoun, Georgia  30701

Re: Mohawk Industries, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2011
Filed February 29, 2012
File No. 001 -13697

Dear Mr. Lorberbaum :

We have reviewed your response dated October 1, 2012  and have the following
additional comment . In our comment , we may ask you to provide us with information so we may
better understand your disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response .  If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing  and the information you provide in
response to  this comment , we may have  additional comments.

Form 10 -K for Fiscal Year Ended December 31, 2011

Financial Statements, page 36

Note (14) Commitments and Contingencies, page 65

1. Based on the information included in your response to comment 1  in our letter dated
September 17, 2012 , it appears that you may have reasonably possible or probable losses
in excess of amounts presently accrued.  In future filings, please disclose the amount or
range of reasonably possible losses in excess of the amounts accrued or provide a
statement that such  an estimate cannot be made as required by ASC 450 -20-50-3 through
50-4.  Alternatively you may disclose, if true, that any such amounts in excess of the
amounts accrued are not material in relation to your financial statements.

Mr. Jeffrey S. Lorberbaum
Mohawk Industries, Inc.
October 31, 2012
Page 2

 You may contact  Sondra Snyd er, Staff accountant , at (202) 551 -3332  or Jason
Niethamer, Assistant Chief Accountant , at (202) 551 -3855  if you have questions regarding  our
comments .  You may  contact me at (202) 551 -3737  with any other questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief