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Alston&Bird llp

One Atlantic Center

1201 West Peachtree Street

Atlanta, GA 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

May 17, 2010

Mr. H. Christopher Owings

Assistant Director

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    Mohawk Industries, Inc.

Definitive Proxy Statement on Schedule 14A, Filed April 5, 2010

File No. 001-13697

Dear Mr. Owings:

     In connection with the review by the Securities and Exchange Commission of the above
referenced filing of Mohawk Industries, Inc. (the “Company”), set forth below are the Company’s
responses to the Staff’s comments contained in the letter dated May 3, 2010 to Jeffrey S.
Lorberbaum, Chairman and Chief Executive Officer of the Company.

General

    1.

    We note that the acknowledgements we requested were provided by counsel on behalf of the
Company. With your next response, please submit a separate letter from the company with the
requested acknowledgements.

Response:

     The Company notes the Staff’s comment and is filing the requested acknowledgements separately.

Definitive Proxy statement on Schedule 14A

Nominees for director, page 2

    2.

    Under this heading and the heading “Continuing Directors” beginning on page 3, you
include other directorships currently held by your directors and director nominees. To
the extent that any of your directors or director nominees have held any other
directorships during the past five years in any company with a class of securities
registered pursuant to section 12 of the Exchange Act or subject to the requirements of
section 15(d) of such Act or

Atlanta • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley • Ventura County • Washington, D.C.

Mr. H. Christopher Owings

May 17, 2010

Page 2

    any company registered as an investment company under the Investment Company Act of 1940, as
amended, please disclose such directorship, including the name of the company. Please refer
to Item 401(e)(2) of Regulation S-K.

Response:

     The Company notes the Staff’s comments. During the past five years, Mr. Bruckmann also
formerly served as a director of Penhall International, Inc. and Anvil Holdings, Inc.; Mr. Fiedler
also formerly served as a director of YRL Worldwide Inc., formerly Yellow Roadway Corp.; Mr. Kolb
also formerly served as a director of Paxar Corp.; Mr. McCurdy also formerly served as a director
of American Axle & Manufacturing Holdings Inc.; and Mr. Pokelwaldt also formerly served as a
director of FirstEnergy Corp.

Compensation Discussion and Analysis, page 12

Elements of our Compensation Program, page 14

Annual Incentives, page 14

    3.

    We note your disclosure in the last paragraph on page 14 that the company funded a bonus pool
equal to 1.25% of consolidated operating income for 2009 and that certain of your named
executive officers would be eligible to receive 20% of the bonus pool while others would be
eligible to receive 12% of the bonus pool. We were unable to calculate the maximum bonuses
set forth on your grants of plan-based awards table based on your reported consolidated
operating income. Please disclose how you calculated these amounts.

Response:

     As discussed with the Staff, the maximum bonuses set forth on the Company’s grants of
plan-based awards table were calculated based on the Company’s consolidated operating income,
excluding the effect of business restructurings, claims and related costs associated with the
Company’s discontinuation of certain carpet tile products, and unusually high raw material costs in
2008 that flowed through the Company’s costs of sales in early 2009, which were determined by the
Compensation Committee in an exercise of its discretion to be appropriate for exclusion. The
Company’s consolidated operating income used for calculating the maximum bonuses set forth on the
grants of plan-based awards table, after adjusting for the excluded items, was $301 million.

Long-Term Incentives, page 16

    4.

    Please disclose the historical EPS Target and the EBITDA Target described under this heading
and how actual results of the peer group compared to the targets for each of your named
executive officers. You may wish to use a
chart or similar presentation for this information. Refer to Item 402(b)(2)(v)

Mr. H. Christopher Owings

May 17, 2010

Page 3

    of Regulation S-K. We also note your disclosure under the heading “Proposed Changes for 2010”
on page 18. Please also confirm to us that you will disclose in future proxy statements
the historical TSR Target and how actual results of the peer group compared to the targets
for each of your named executive officers.

Response:

     The Company notes the Staff’s comments. For both 2009 and 2010, the LTIP compares the
Company’s performance on the stated measures against the average performance of the peer group on
the same measure for the same period. There are no “historical” targets, only reference to the
performance of the peer group during the same year. So, for example, in determining the payouts
under the LTIP for performance in 2009, the Compensation Committee compared the average EPS growth
of the peer group for 2009 against the Company’s EPS growth for 2009, then compared the average
EBITDA of the peer group for 2009 as a percentage of tangible assets against the same metric for
the Company. In both instances, the Company’s performance was below the 25th percentile of the
peer group and therefore no awards were earned for 2009 based on this performance measure. In
2010, the same process will be used but with total shareholder return as the sole metric.

Corporate Governance, page 28

General, page 28

    5.

    Please disclose, on an individual basis, the specific experience, qualifications, attributes
or skills of each director and director nominee that led to the conclusion that each such
person should serve as a director. Please refer to Item 401(e)(1) of Regulation S-K. For
additional guidance, please also refer to Regulation S-K Compliance and Disclosure
Interpretations, Question and Answer 116.05, available at
www.sec.gov/divisions/corpfin/guidance/regs-kinterp.htm.

Response:

     In response to the Staff’s comment regarding the Company’s disclosure on page 28, which
specifies the specific experience, qualifications, attributes and skills of each director, in
addition to those included in the biographical summary for each director and cross-referenced on
page 28, the Company proposes to revise such disclosure as follows:

    •

    Mr. Lorberbaum, our Chairman and CEO, brings over 30 years of management and
executive experience in the carpet industry and is a significant stockholder.

Mr. H. Christopher Owings

May 17, 2010

Page 4

    •

    Mr. Wellborn brings over 15 years of executive and financial experience in the
manufacturing sector, with over 12 years of such experience with Dal-Tile and the
Company.

    •

    Mr. DeCock was CEO of Unilin at the time of its acquisition by the Company, and
he served in various executive and management positions with Unilin over many
years. He brings unique and strong knowledge of the European and laminate flooring
industries.

    •

    Ms. Bonanno brings executive experience in the consumer products sector, as well
as broad international business and trade experience in both public and private
sectors, together with service on other public company boards of directors.

    •

    Mr. Bruckmann, also a significant stockholder in the Company, brings significant
experience in corporate finance and capital markets, together with service on other
public company boards of directors.

    •

    Mr. Fiedler brings experience as a Chairman and CEO with a public, global
manufacturing company, many years of operational and executive experience in the
manufacturing sector and service on other public company boards of directors.

    •

    Mr. Kolb has over 20 years of management and executive experience in the carpet
industry, is a former Chairman and CEO of the Company and is a significant
stockholder in the Company. He also serves on other public company boards of
directors.

    •

    Mr. McCurdy brings experience as a CEO with two manufacturing companies, one of
which is a public company and for which he also served for a time as Chairman.
Additionally, Mr. McCurdy brings many years of executive, financial and operational
experience in the manufacturing sector and service on other public company boards
of directors.

    •

    Mr. Onorato brings significant executive and financial experience with public,
global manufacturing companies, including service as both a Chief Financial Officer
and as a Treasurer, together with service on another public company board of
directors.

    •

    Mr. Pokelwaldt brings experience as a Chairman and CEO with a public, global
manufacturing company, many years of executive and operational experience in the
manufacturing sector and service on other public company boards of directors.

Mr. H. Christopher Owings

May 17, 2010

Page 5

     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:

    Catherine Brown

Jeffrey S. Lorberbaum

Frank H. Boykin

James T. Lucke

James F. Brunk