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Alston&Bird
LLP

One Atlantic Center

1201 West Peachtree Street

Atlanta, Georgia 30309-3424

404-881-7000

Fax: 404-881-7777

www.alston.com

R. David Patton                                               Direct
Dial: 404-881-7951                   E-mail: dave.patton@alston.com

August 16, 2007

Mr. James Allegretto

Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, D.C. 20549

  Re:

  Mohawk Industries, Inc.

  Form 10-K for Fiscal Year Ended December 31, 2006, Filed
  February 26, 2007

  Forms 10-Q for Fiscal Quarters Ended March 31, 2007 and
  June 30, 2007,

  Filed May 10, 2007 and August 1, 2007

  File No. 1-13697

Dear Mr. Allegretto:

   In connection with the review by the
Securities and Exchange Commission of the above referenced filings of Mohawk
Industries, Inc. (the "Company") set forth below are the Company's responses to
the Staff's comments contained in the letter dated August 2, 2007 to Frank H.
Boykin, Chief Financial Officer of the Company.

Form 10-K for the Fiscal year Ended
December 31, 2006

Business

General, page 3

In
future filings, please expand your discussion to provide the information
required under Item 101(c)(1)(i) of Regulation S-K pertaining to your principal
products for each of the last three fiscal years.

Response:  The Company has three
categories of similar products accounting for 10% or more of consolidated
revenue in the last three fiscal years.  These three categories are:
(1) Soft surface, which includes carpets, rugs, carpet pad and resilient;
(2) Tile, which includes ceramic tile, porcelain tile and natural stone;
and (3) Wood, which includes laminate, hardwood, roofing panels and
wood-based panels.  In response to this comment, the Company will include
disclosure required under Item 101(c)(1)(i) of Regulation S-K for these three
categories in future filings.

  Bank of
  America Plaza

  101
  South Tryon Street, Suite 4000

  Charlotte,
  NC 28280-4000

  704-444-1000

  Fax:
  704-444-1111

  90 Park
  Avenue

  New
  York, NY 10016

  212-210-9400

  Fax:
  212-210-9444

  3201
  Beechleaf Court, Suite 600

  Raleigh,
  NC 27604-1062

  919-862-2200

  Fax:
  919-862-2260

  The
  Atlantic Building

  950 F
  Street, NW

  Washington,
  DC  20004-1404

  202-756-3300

  Fax:
  202-756-3333

Mr. James Allegretto

August 16, 2007

Page 2

Income Taxes, page 59

Please provide us with a description of the nature of the "Belgium Notional
interest" reconciling item included in the tabular presentation at page 60 of
the differences between the amounts of income tax expense attributable to
earnings before income taxes and the amounts computed by applying the U.S.
statutory federal income tax rate to earnings before income taxes.

Response:  Effective for tax years
beginning in 2006, Belgian tax law permits a corporate tax deduction based on a
Belgian company's equity multiplied by a published government interest rate.
The Belgium Notional Interest reconciling item included on page 60 quantifies
the Company's consolidated deduction pursuant to these provisions.

Commitment and
Contingencies, page 62

We
note your disclosure that you believe that "adequate provisions for resolution
of all claims and pending litigation have been made for probable losses and
that the ultimate outcome of these actions will not have a material adverse
effect on [your] financial condition but could have a material effect on [your]
results of operations in a given quarter or annual period."  Particularly with
regard to the legal proceeding you cite as material, please expand your
discussion to disclose the amounts of reserves you have recorded.  Also ensure
that you have provided all applicable disclosures under paragraphs 8-10 of SFAS
5 including an estimate of the possible loss or range of loss or a statement
that such an estimate cannot be made.

Response:  The Company believes that
it has properly accrued for the Williams case pursuant to Statement of
Financial Accounting Standards No. 5 ("SFAS No. 5") and provided the
disclosures required by SFAS No. 5.  As required by paragraph 8 of SFAS No. 5,
the Company has accrued a reasonable estimate of the probable loss pursuant to
the Williams case.  Pursuant to paragraph 9 of SFAS No. 5, the Company's
management believes that disclosure of the specific amount of the accrual the
Company has made pursuant to the provisions of SFAS No. 5 is not necessary for
the Company's consolidated financial statements not to be misleading.  Further,
the Company respectfully submits that disclosure of the specific amount of the
accrual will impair the Company's ability to effectively defend itself and minimize
the amount of any loss in the Williams case.  As the Company continues to
vigorously defend itself against this action, it will continue to evaluate the
likelihood of an additional loss in excess of the amount accrued to date for
the Williams case and, to the extent an additional significant loss becomes
reasonably possible, will provide the disclosures required by paragraph 10 of SFAS
No. 5.

Mr. James Allegretto

August 16, 2007

Page 3

Controls and Procedures,
page 67

 We note your statement that management does not expect
     that "[your] disclosure controls and procedures or your internal control
     over financial reporting will prevent all errors and all fraud.  A control
     system, no matter how well conceived and operated, can provide only
     reasonable, not absolute, assurance that the objectives of the control
     system are met."  Please confirm, if true, that your controls and
     procedures were designed at the reasonable assurance level and that your
     principal executive officer and principal financial officer concluded that
     your disclosure controls and procedures are effective at the reasonable
     assurance level.  If so, please revise your disclosure accordingly in
     future filings.  In the alternative, remove the reference to the level of
     assurance of your disclosure controls and procedures included in your current
     disclosure. Please refer to Section II.F.4 of Management's Reports on
     Internal Control Over Financial Reporting and Certification of Disclosure
     in Exchange Act Reports, SEC Release No. 33-8238, available on our website
     at  http://www.sec.gov/rules/final/33-8238.htm

Response:  The language quoted by
the Staff in its comment and contained in the Company's Form 10-K is intended
to educate the reader as to the limitations inherent in any company's
disclosure controls and procedures.  We respectfully submit that the process
undertaken by the Company and its Chief Executive Officer and Chief Financial
Officer meets the applicable legal requirements and guidance relating to the
evaluation of disclosure controls and procedures.  The Company hereby confirms
that its controls and procedures were designed at the reasonable assurance
level and its principal executive officer and principal financial officer
concluded that its disclosure controls and procedures were effective at the
reasonable assurance level.  The Company will revise its disclosure in future
filings to make it clear that its disclosure controls and procedures were
designed to provide "reasonable assurance . . ." as requested by the
Staff.

            In connection with these responses to the
Staff's comments, the Company acknowledges 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
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.

Mr. James Allegretto

August 16, 2007

Page 4

Thank
you for your consideration of the Company's responses to the Staff's comments
and we appreciate your review and assistance.  If you have any questions
regarding these responses, please do not hesitate to call the undersigned
(404-881-7951) or James T. Lucke, General Counsel of Mohawk (706) 624-2660.

Very truly yours,

/s/: R. David Patton

       R. David
Patton

  cc:
    Regina Balderas
  (Securities and Exchange Commission)

  Frank H. Boykin (Mohawk
  Industries, Inc.)

  James T. Lucke (Mohawk
  Industries, Inc.)