SecProbe.io

Mail Stop 3561

August 20, 2015

Mohawk Industries, Inc.
Frank H. Boykin
Chief Financial Officer
160 S. Industrial Blvd.
Calhoun, Georgia  30701

Re: Mohawk Industries, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2014
Filed February 27, 2015
File No. 1-13697

Dear Mr. Boykin :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to your facts and circumstances , please tell us why in your response.

After review ing your response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2014

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Overview, page 20

1. Based on your disclosures on page 63, we note that you generated 50% of your pretax
income from foreign operations in fiscal year 2014.    Please tell us what consideration
you gave to separately discussing the results and trends of the geographic regions and/ or
countries in which you operate.   We note that management discusses geographic results
and trends during quarterly earnings calls and it appears such information would be
useful to investors.  Please also disclose, if material, revenues and long -lived a ssets by
individual country.  Refer to the guidance in Item 101(d) and Item 303 of Regulation S -K
and SEC Release No. 33 -8350.

Frank H. Boykin
Mohawk Industries, Inc.
August 20, 2015
Page 2

 Year Ended December 31, 2014, as Compared with Year Ended December 31, 2013

Gross Profit, page 22

2. Tell us what consideration y ou gave to expanding your gross profit discussion to provid e
more insight into the factors underlying the change in your cost of sales  and the material
trends and uncertainties associated with your cost of sales .  In this regard, we note cost of
sales is a material expense for you  and we assume it could potentially vary across your
three segments.  Your current analysis of cost of sales within your analysis of gross profit
appears relatively brief.  Refer to Item 303(a)(3)(i) of Regulation S -K.

Selling, general and administrative expenses, page 22

3. Please discuss SG&A on an absolute basis in addition to relative to sales.  While we
expect that most selling costs track closely with changes in sales, we assume that general
and administrative costs are effectively fixed within certain ranges of sales volume.
Therefore, we believe it would be meaningful to discuss the nature an d amount of the
dollar changes in such costs, if material, and the specific factors driving those changes.
Please also quantify the impact of foreign exchange rates on SG&A expense.

Income tax expense, page 23

4. Based on your income tax footnote discl osures, it appears that there is a significant
disparity in the effective tax rates of your domestic and international operations.  Please
revise your discussion to separately discuss the reasons for fluctuations in domestic and
foreign effective tax rates  and consider quantifying your domestic and foreign effective
tax rates.  If a particular country contributes disproportionately to your income based on
significantly lower tax rates, explain the impact such tax structures had on your results.
If changes in the geographical mix of income were a significant driver of changes in your
effective tax rate, please explain to us and disclose the facts and circumstances leading to
the changes in the geographical mix of income and whether you expect these changes t o
continue.  In this regard, an overview of how your effective tax rate may be impacted by
a mix of earnings among your domestic and foreign operations would appear useful to an
investor.  We refer you to Item  303(a)(3)(i) of Regulation S -K and Section III .B of SEC
Release No. 33 -8350.

Liquidity and Capital Resources, page 25

5. Please provide a comparative discussion of each section of your cash flows (i.e.,
operating, financing, and investing) between all comparable periods presented in the
statements of c ash flows.   For example, there is no discussion of cash flows between
fiscal years 2013 and 2012.   Your discussion should be accompanied by an analysis at an
appropriate  level of detail that is not just a recitation of changes evident from the
financial st atements.   Please note that in regard to operating cash flows your analysis

Frank H. Boykin
Mohawk Industries, Inc.
August 20, 2015
Page 3

 should focus on factors that directly affect cash, and not merely refer to higher
earnings.   Refer to Section IV.B of SEC Release No. 33 -8350.

Item 8. Consolidated Financial State ments and Supplementary Data

(1) Summary of Significant Accounting Policies, page 41

General

6. We note your disclosure on page 12 that you may have difficulty repatriating cash from
non-U.S. subsidiaries.  Please tell us how you considered the guidance in  Rule 4 -08(e)(3)
of Regulation S -X with respect to providing footnote disclosure about the nature and
amount of significant restrictions on the ability of subsidiaries to transfer funds to the
parent through intercompany loans, advances or cash dividends.  Please refer to SAB
Topic 6K for further guidance.

(11) Product Warranties, page 56

7. Although paid warranty claims have decreased approximately 6% since fiscal 2012, your
warranty expense has decreased approximately 22% over that timeframe.  Please exp lain
to us why warranty expense decreased at a much greater percentage over the last three
years than paid warranty claims.

(13) Employee Benefit Plans, page 60

8. We note that a Belgian pension plan “no longer qualified as a defined benefit plan”
during 2 014.  Please tell us the cause of this change, how you accounted for the plan
during 2014, and quantify for us the materiality of this plan on your historical financial
statements.

(15) Income Taxes, page 63

9. We note the significance of the “Foreign income taxes” line item within your tax rate
reconciliation.  Please tell us the nature of the items included within this line item and, if
it includes amounts that do not relate to the difference in tax rates betwe en foreign and
domestic operations, please segregate this line item into additional categories.

(16) Commitments and Contingencies, page 66

10. We note from your second quarter Form 10 -Q contingency footnote that you recorded a
$125 million charge during t he first quarter of 2015 related to the settlement and defense
of your U.S. and Canadian antitrust cases.  Please tell us the amount accrued for these
matters at December 31, 2014.  Considering you had an agreement in principle to settle
the Canadian actio ns at the time you filed your Form 10 -K and the U.S case was settled

Frank H. Boykin
Mohawk Industries, Inc.
August 20, 2015
Page 4

 shortly after the filing date, also clarify why you were unable to estimate the amount or
range of loss, if any, in excess of amounts accrued.

(18) Segment Reporting, page 68

11. We n ote you present geographic net sales and long -lived assets for “North America” and
the “Rest of World.”  We also note the significant increase in Rest of World sales over
the last three fiscal years.  Given the materiality of your foreign operations, tell us what
consideration you gave to separately disclosing net sales and long -lived assets of
individual foreign countries, where material, as noted in ASC 280 -10-50-41.

We urge all persons who are responsible for the accuracy and adequacy of the disclosu re
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosu re, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy o f the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

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

You may contact Robert Babula, Staff Accountant at  (202) 551 -3339  or Andrew Blume,
Staff Accountant at (202) 551 -3254  if you have questions regarding comments on the financial
statements and related matters.  Please contact  me at (202) 551 -3737  with any other questions.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief
Office of Consumer Products