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 January 13, 2026

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Manufacturing

 100 F Street, NE

 Washington, D.C. 20549

 Attn: Ms. Anne McConnell

 Mr. Hugh West

 Re: Mohawk Industries, Inc.

 Form 10-K for Fiscal Year Ended December 31, 2024

 Filed February 20, 2025

 File No. 001-13697

 Dear Ms. McConnell and Mr. West:

 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 December 19, 2025, to James F. Brunk, Chief Financial
Officer of the Company.

 The Staff's comments are set forth below in italics, followed
by our responses to the 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 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.

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South Industrial Blvd. S.W. • P.O. Box 12089 • Calhoun, Georgia 30703-7002 • (800) 241-4494

 U.S. Securities and Exchange Commission January 13, 2026 Page 2

 • 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 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.

 Response:

 As described in Critical Accounting Policies in the Company's
Form 10-K for the fiscal year ended December 31, 2024, the Company has identified Global Ceramic, Flooring North America ("Flooring
NA") and Flooring Rest of the World ("Flooring ROW") as its reporting units for the purposes of allocating goodwill
as well as assessing impairments. As of the Company's 2024 annual goodwill impairment testing date, which was the first day of the
fourth quarter of 2024 (the "2024 Annual Impairment Test Date"), the Company completed quantitative goodwill impairment tests
(the "Annual Impairment Tests") and determined that the estimated fair values of its reporting units with goodwill exceeded
their carrying values and that the Company did not have any at-risk reporting units. Additionally, on an interim basis the Company assesses
if a triggering event has occurred that might reduce the fair value of a reporting unit below its carrying value in accordance with ASC
350-20-35-3C. The Company did not identify any triggering events during the year ended as of December 31, 2024.

 In 2025, the Company did not perform impairment tests at an interim
date as no triggering events or circumstances were identified that might reduce the fair value of a reporting unit below its carrying
value. The Company completed quantitative goodwill impairment tests for the Flooring NA and Flooring ROW reporting units as of the Company's
2025 annual goodwill impairment testing date, which was the first day of the fourth quarter of 2025 (the "2025 Annual Impairment
Test Date").

 The percentages by which estimated fair values exceeded carrying value
as of the 2024 Annual Impairment Test Date for each reporting unit is as follows ($ in millions):

 Reporting Unit
 Estimated Fair Value
 Carrying Value
 Excess Estimated Fair Value
 Percentage Excess Estimated Fair Value

 Flooring NA
 $4,634
 $3,101
 $1,533
 49.5%

 Flooring ROW
 $3,596
 $3,244
 $352
 10.9%

 160
South Industrial Blvd. S.W. • P.O. Box 12089 • Calhoun, Georgia 30703-7002 • (800) 241-4494

 U.S. Securities and Exchange Commission January 13, 2026 Page 3

 Although the Flooring ROW excess is only 11%, the Company does not
believe the reporting unit is at risk. This assessment is based on the fact that Flooring ROW is currently experiencing a cyclical downturn
in performance, and the long-term outlook remains positive. Third-party economic data supports anticipated recoveries in the housing market
and projected reductions in interest rates, which are expected to drive growth in residential remodeling The Company also performed a
quantitative analysis to support the qualitive factors by applying sensitivities to assumptions and inputs used in measuring the reporting
unit's fair value which resulted in the fair value exceeding the carrying value.

 The disaggregation of the Company's goodwill balance of $1,112.1
million as of December 31, 2024, is as follows:

 $ in millions

 Global Ceramic
 -

 Flooring NA
 372.3

 Flooring ROW
 739.8

 Total
 1,112.1

 Consistent with historical practice, in connection with the Company's
2024 Annual Impairment Tests, the Company engaged a third-party valuation specialist to assist with impairment testing. Quantitative tests
were performed for the Company's reporting units. The quantitative tests utilized both an income approach using management judgments
and assumptions regarding discounted cash flows as well as a comparable company market valuation approach. These two approaches were equally
weighted to determine an overall estimated fair value.

 The Company also completed additional valuation procedures on the Global
Ceramic reporting unit as well as certain Corporate segment operations not allocated to reporting units. Finally, a market capitalization
reconciliation was performed to corroborate the estimated fair values of all of the reporting units. For more information on the methods
and key assumptions used to estimate fair values as well as the degree of uncertainty associated with key assumptions, please see the
Company's proposed Critical Accounting Policies disclosure below.

 As of the 2024 Annual Impairment Test Date, the Company's market
capitalization of $10,023M exceeded the Company's net book value of equity of $7,856M by $2,167M. As of December 31, 2024, the Company's
market capitalization declined to $7,519M, and the Company's net book value of equity was $7,557M. Therefore, as of December 31,
2024, the Company's book value was $38M greater than market capitalization ($38M excess book value). As of December 31, 2024, the
Company performed an updated market capitalization reconciliation, along with other analyses on potential triggering events in ASC 350-20-35-3C,
and concluded that it was not more-likely-than-not that the fair values of the Flooring NA or Flooring ROW reporting units were less than
their carrying values as of December 31, 2024, and therefore no additional goodwill impairment testing needed to be performed as of December
31, 2024.

 160
South Industrial Blvd. S.W. • P.O. Box 12089 • Calhoun, Georgia 30703-7002 • (800) 241-4494

 U.S. Securities and Exchange Commission January 13, 2026 Page 4

 A summary of the results of the Annual Impairment Test as of the 2024
Annual Impairment Test Date is as follows ($ in millions):

 Reporting Unit
 Estimated Fair Value

 Global Ceramic and Corporate
 2,553

 Flooring NA
 4,634

 Flooring ROW
 3,596

 Total Estimated Fair Value
 10,783

 Plus: Total Debt
 2,182

 Estimated Total Invested Capital
 12,965

 Market Capitalization
 10,023

 Plus: Total Debt
 2,182

 Market Total Invested Capital
 12,205

 Implied TIC Control Premium
 6.2 %

 The Company also performed sensitivity analyses on the implied control
premium by using share prices 15-days as well as 30-days prior to the 2024 Annual Impairment Test Date and noted implied TIC control premiums
of 8.5 to 9.3%, which is the low end of the range of transaction control premiums. These implied TIC control premiums are considered well
within reasonable ranges.

 In consideration of the Staff's comments, the Company believes
that it is reasonably possible that an impairment charge could materially impact our financial statements. As such, the Company proposes
to provide the additional disclosures below in the Critical Accounting Policies section of its Form 10-K for the fiscal year ended December
31, 2025.

 Critical Accounting Policies

 In accordance with the provisions of the FASB ASC Topic 350, Intangibles-Goodwill
and Other , the Company tests goodwill and other intangible assets with indefinite lives, which for the Company are tradenames, for
impairment on an annual basis on the first day of the fourth quarter (or on an interim basis if a triggering event occurs that might reduce
the fair value of the reporting unit below its carrying value). Such triggering events or circumstances could include a significant change
in the business climate, legal factors, operating performance or trends, competition, or sale or disposition of a significant portion
of a reporting unit.

 160
South Industrial Blvd. S.W. • P.O. Box 12089 • Calhoun, Georgia 30703-7002 • (800) 241-4494

 U.S. Securities and Exchange Commission January 13, 2026 Page 5

 In 2025, the Company did not perform impairment tests at an interim
date as no triggering events or circumstances were identified that might reduce the fair value of the reporting unit below its carrying
value.

 The goodwill impairment tests are based on determining the fair value
of the specified reporting units relying on management judgments and assumptions using the discounted cash flows under the income approach
classified in Level 3 of the fair value hierarchy and comparable company market valuation classified in Level 2 of the fair value hierarchy.
The valuation approaches are subject to key judgments and assumptions that are sensitive to change, such as judgements and assumptions
about appropriate sales growth rates, operating margins, Weighted Average Cost of Capital ("WACC"), capital expenditures and
comparable company market multiples.

 The Company completed quantitative goodwill impairment tests for the
Flooring NA and Flooring ROW reporting units in 2025. In determining the fair value of the reporting units, the Company used both an income
approach and market approach to estimate the fair value of the reporting units, and with both approaches weighted equally when determining
the estimated fair value. The Company engaged a third-party valuation specialist to assist in developing these estimated and valuation
approaches.

 · Under the income approach, estimated future discounted cash flows were used
to estimate the fair value of the reporting unit. The income approach required the Company's management to make certain market participant
key assumptions such as growth rates, operating margins, and WACC and capital expenditures.

 · Under the market approach, the Company estimated the fair value of a reporting
unit based on market multiples of earnings for benchmark companies that have similar risks, participate in similar markets and compete
with the Company directly.

 · Valuation multiples were selected based on a financial benchmarking analysis
that compared each reporting unit's operating results with the comparable companies' information. In addition to these financial
considerations, qualitative factors such as variations in growth opportunities and overall risk among the benchmark companies were considered
in the ultimate selection of the multiple.

 In order to corroborate the estimated fair value conclusions of the
Company's reporting units, the Company combined the estimated fair values for all reporting units and performed a market capitalization
reconciliation to assess the reasonableness of the implied control premium. The Company also compared its market capitalization to net
book value of equity to assess the implied control premium for reasonableness. The Company also applied sensitivities to assumptions and
inputs used in measuring the reporting unit's fair value to address estimation uncertainty.

 The Company has not made any material changes to the valuation methodology
utilized to assess goodwill impairment since the date of its last annual impairment test, which is the first day of the fourth quarter
of 2025.

 The Company determined the fair value of each of our reporting units
exceeded their respective carrying values as of the date of its last annual impairment test.

 The Company will continue to monitor the performance of the reporting
units to ensure no interim indications of possible impairment have occurred before the next annual goodwill impairment assessment at the
beginning of the fourth quarter of 2026.

 160
South Industrial Blvd. S.W. • P.O. Box 12089 • Calhoun, Georgia 30703-7002 • (800) 241-4494

 U.S. Securities and Exchange Commission January 13, 2026 Page 6

 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).

 Response:

 The Company respectfully acknowledges the Staff's comment and
explains that while segment Gross profit (loss) is included in the financial information that is provided to the CODM for informational
purposes, the CODM does not use segment Gross profit (loss) when assessing performance and allocating resources. The CODM uses the segment
Operating income (loss) to allocate resources and assess performance. Therefore, the Company believes it is the metric required to be
disclosed under the guidance in ASC 280-10-50-28A. In future filings, the Company plans to present only this required measure.

 To address the Staff's comment and limit confusion on the metric
used by the CODM in future filings, the Company will revise Note (17) to re