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 December 19, 2025

James Brunk
Chief Financial Officer
MOHAWK INDUSTRIES INC
160 S. Industrial Blvd.
Calhoun, Georgia 30701

 Re: MOHAWK INDUSTRIES INC
 Form 10-K for the fiscal year ended December 31, 2024
 Filed February 20, 2025
 File No. 001-13697
Dear James Brunk:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Critical Accounting Policies, page 33

1. We note that you recorded material goodwill and intangible asset
impairment charges
 in prior periods. We also note that the assessment of goodwill for
impairment is
 identified by your auditor as a critical audit matter in their audit
report. Based on the
 continued materiality of goodwill and intangible assets to your
financial statements,
 underlying negative operating trends, and the fact that your net book
value exceeds
 your market capitalization, please more fully explain to us how you
determined the
 estimated fair values of your reporting units exceed their carrying
values. In addition,
 to the extent you conclude an impairment charge that could materially
impact your
 financial statements is reasonable possible, expand your disclosures to
address the
 following:
 Disclose whether you performed an impairment test since your most
recent annual
 December 19, 2025
Page 2

 impairment test and explain why or why not.
 Disclose the number of reporting units with goodwill and state
whether you
 performed quantitative or qualitative impairment tests as of the
most recent
 impairment test date.
 Disclose the percentages by which estimated fair values exceeded
carrying value,
 as of the most recent impairment test date, for each at risk
reporting unit.
 Disclose the amount of goodwill and the amount of intangible
assets allocated to
 each at risk reporting unit.
 More fully describe the methods and key assumptions used to
estimate fair values,
 including how key assumptions are determined and how key assumptions
changed
 changed over relevant periods, including the reasons why they
changed.
 More fully discuss the degree of uncertainty associated with key
assumptions,
 including specifics to the extent possible.
 More fully describe the potential events and/or changes in
circumstances that
 could reasonably be expected to negatively affect each key
assumption.
 Explain if, and how, you consider differences between net book
value and market
 capitalization in assessing the reasonableness of the estimated fair
values of your
 reporting units.
Item 8. Consolidated Financial Statements and Supplementary Data
Notes to the Consolidated Financial Statements
(17) Segment Reporting, page 76

2. We note you present both gross profit (loss) and operating income (loss).
Please
 clearly identify the measure or measures of a segment s profit or loss
that the chief
 operating decision maker uses in assessing segment performance and
deciding how to
 allocate resources. If the CODM uses more than one measure of a segment
s profit or
 loss in assessing segment performance and deciding how to allocate
resources,
 disclose the measure required to be reported, which is the measure that
management
 believes is determined in accordance with the measurement principles most
consistent
 with those used in measuring the corresponding amounts in the
consolidated financial
 statements. For each measure of a segment s profit or loss used by the
CODM, please
 disclose and discuss how the CODM uses the measure in assessing segment
 performance and deciding how to allocate resources. Refer to ASC
280-10-50-28A,
 50-29(f) and 55-47(bb).
3. We note you disclose selling, general and administrative expenses by
segment. Please
 tell us whether any other significant segment expenses are regularly
provided to the
 CODM or easily computable from information that is regularly provided to
the
 CODM. In particular, tell us your consideration of presenting cost of
sales by
 segment, which is easily computable from gross profit and net sales. In
addition, for
 each reportable segment, disclose an amount for other segment items,
along with a
 description of the composition of other segment items. Refer to ASC
280-10-50-26A,
 50-26B and 55-15B.
 December 19, 2025
Page 3
4. Please provide reconciliations of the totals of your reportable
segments' measures of
 profit or loss to your consolidated income before income taxes, in
accordance with
 ASC 280-10-50-28C and 50-30(b).

 In closing, we remind you that the company and its management are
responsible for
the accuracy and adequacy of their disclosures, notwithstanding any review,
comments,
action or absence of action by the staff.

 Please contact Anne McConnell at 202-551-3709 or Hugh West at
202-551-3872 with
any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Manufacturing
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