SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                                             May 21, 2007
 Mac McConnell Senior Vice President and Chief Financial Officer DXP Enterprises, Inc. 7272 Pinemont Houston, Texas 77040
 RE: DXP Enterprises, Inc.
Form 10-K for Fiscal Year  Ended December 31, 2006
Form 10-Q for Fiscal Quarter Ended March 31, 2007
File No. 0-21513

Dear Mr. McConnell:

We have reviewed your letter date d May 10, 2007 and have the following
comments.  Where indicated, we think you should revise your disclosures in response to
these comments.  If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unneces sary.  Please be as detailed as necessary
in your explanation.  Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requir ements and to enhance the
overall disclosure in your filing.  We look forw ard to working with you in these respects.
We welcome any questions you may have about our comments or on a ny other aspect of
our review.  Feel free to call us at the phone numbers listed below.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2006

 General

1. Where a comment below requests additional disclosures or other revisions, please
show us what the revisions will look like in your supplemental response.  All
revisions should be included in your future  filings, including your interim filings
where appropriate.

Financial Statements
 3. Acquisitions

2. We have read your response to comment  four from our letter dated April 23,
2007.  You indicate that the weighted average useful life for the vendor

Mr. Mac McConnell
May 21, 2007 Page 2
agreements was 20 years.  Please tell us how you determined that twenty years is
the appropriate useful life of your ve ndor agreements in accordance with
paragraph 11 of SFAS 142.  Please also provide the disclosures for intangible
assets as required by paragraph 44 of SFAS 142.
 3. We have read your response to comment five from our letter  dated April 23, 2007.
Please tell us what types of intangible a ssets are included in your estimate of
intangible assets related to the 2006 acquisi tions.  Please also tell us and disclose
the useful life of each major intangible asse t class included in your estimate.
 4. Inventories

4. We have read your response to comment  six from our letter dated April 23, 2007.
Please show us what your revised disclosure will look like.
 9. Commitments and Contingencies

 5. We have read your response to comment  seven from our letter dated April 23,
2007.  You indicate that you do not believe that additional losses exceeding $20
are reasonably possible.  However, it is st ill unclear whether you believe losses in
the range of $0 to $20 million are reasonably possible.  If true, please disclose
your belief that losses rela ted to these pending claims ar e not reasonably possible.
Otherwise, please revise your discussi on to include each of the disclosures
required by paragraph 10 of SFAS 5 and question 2 in SAB Topic 5:Y.

*    *    *    *

Please respond to these comments within  10 business days, or tell us when you
will provide us with a response.  Please provi de us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.
You may contact Ernest Greene, Staff Accountant, at (202) 551-3733, or the
undersigned at (202) 551-3769, if you have questions regarding comments on the
financial statements and related matters.         Sincerely,            R u f u s  D e c k e r
       Accounting Branch Chief