SecProbe.io

Mail Stop 3561
June 7, 2016

Frank H. Boykin
Chief Financial Officer and Vice President -Finance
Mohawk Industries , Inc.
160 S. Industrial Blvd.
Calhoun, Georgia 30701

Re: Mohawk Industries, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2015
Filed February 29, 2016
File No. 001 -13697

Dear Mr. Boykin :

We have limited our review  of your filing  to the financial statements and related
disclosures and 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 reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for the Fiscal Year Ended December 31, 2015

Item 6. Selected Financial Data , page 20

1. We note you changed your calculation of working capital such that it now appears to
exclude the current portion of long -term debt.  Please tell us the reasons  for excluding the
current portion of long -term debt in your calculation of working capital.  Please also tell
us your consideration for providing the disclosures required by Item 10(e)(1)(i) of
Regulation S -K related to the use of this measure, or explain  to us how your calculation
of working capital is consistent with the definitions of working capital and current
liabilities in the ASC Master Glossary.

Frank H. Boykin
 Mohawk Industries, Inc.
 June 7, 2016
 Page 2

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

Year  Ended December 31, 2015, as Compared with Year Ended December 31, 2014 , page 24

2. We note from the remarks made by management during the fourth quarter 2015 earnings
call that the carpet industry is experiencing decreasing average prices and a lower growth
rate.  While you broadly discuss changes in pricing and volume for each segment, if
material to  any of your segments, please separately discuss the impact of changes in price
and volume for your carpet business on your results, particularly on your sales and gross
profit, as well as known material trends related to this business.  Refer to Item
303(A)(3)(ii) and (3)(iii) of Regulation S -K.

Item 8. Consolidated Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

(9) Long -Term Debt, page 56

3. We note that your 2015 Senior Credit Facility restricts “dividends and other similar
restricted payment.”  Please tell us how you considered the applicability of the disclosure
requirements of Rule 4 -08(e) of Regulation S -X and Sch edule I as described in Rule 5 -04
of Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
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 disclosure, 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 of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not forec lose
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.

Frank H. Boykin
 Mohawk Industries, Inc.
 June 7, 2016
 Page 3

 You may contact Melissa Blume, Staff Accountant at (202) 551 -7128 or Jennifer
Thompson, Accounting Branch Chief at (202) 551 -3737, if you have questions regarding
comments on the financial statements and related matters.  Please contact me at (202) 551 -3849
with any other questions.

Sincerely,

 /s/ Jim Allegretto

Jim Allegretto
Senior Assistant Chief Accountant
Office of Consumer Products