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CORRESP
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      Response dated 05-22-2007 to SEC Correspondence

    May
      22,
      2007

    VIA
      FACSIMILE: 202-772-9368

    Mr.
      Ernest Greene

    Staff
      Accountant

    Division
      of Corporation Finance

    United
      States Securities and Exchange Commission

    Washington,
      DC 20549-7010

    RE:  DXP
      Enterprises, Inc.

Form
      10-K
      for Fiscal Year Ended December 31, 2006

File
      No.
      0-21513

    Dear
      Mr.
      Greene:

    I
      have
      reviewed the comments contained in your letter to me dated May 21, 2007. My
      responses are keyed to your comments.

    3. Acquisitions

    2. The
      two
      vendor agreements under discussion are Goulds Pumps and Viking Pump. The
      acquired company has been a distributor of Goulds Pumps since 1986 and Viking
      Pump since 1971. According to industry sources these two pump manufacturers
      rarely terminate distribution agreements. DXP expects the distribution
      agreements with these two vendors to contribute to cash flows for at least
      the
      next twenty years.

    Following
      are the example disclosures for intangible assets as required by paragraph
      44 of
      SFAS 142 which will be included in future filings:

    Goodwill
      and Other Intangible Assets

    Goodwill
      and other intangible assets attributable to our reporting units are tested
      for
      impairment by comparing the fair value of each reporting unit with its carrying
      value. Significant estimates used in the determination of fair value include
      estimates of: future cash flows, future growth rates; costs of capital and
      market multiples. As required under current accounting standards, we test for
      impairment annually at year end unless factors otherwise indicate that
      impairment may have occurred. We did not have any impairments under the
      provisions of SFAS No. 142 as of December 31, 2006.

    Goodwill
      totaled $15.1 million at December 31, 2006 and represents the excess of the
      Company’s purchase cost over the fair value of the net assets of acquired
      businesses, net of previously recorded amortization and impairment expense.
      The
      net book value of other intangible assets at December 31, 2006 was $7.7 million.
      Other intangible assets consist primarily of the value assigned to such items
      as
      customer relationships and vendor agreements in connection with the allocation
      of purchase price for acquisitions under SFAS No. 142. Other intangible assets
      are generally amortized on a straight-line basis over their expected useful
      lives. No amortization expense was recorded in 2005 and 2004. All goodwill
      and
      other intangible assets pertain to the MRO segment.

    A
      summary
      of goodwill and other intangible assets follows:

    Acquired
      Other Intangible Assets

              As
                of December 31, 2006

              Gross
                Carrying

              Amount

              Accumulated

              Amortization

              Amortized
                intangible assets

              Vendor
                agreements

              $3,281

              $
                (178)

              Customer
                relationships

              5,069

              (441)

              Total

              8,350

              (619)

              Aggregate
                Amortization Expense:

              For
                year ended 12-31-2006

              $
                646

              Estimated
                Amortization Expense:

              For
                year ended 12-31-2007

              $
                760

              For
                year ended 12-31-2008

              $
                760

              For
                year ended 12-31-2009

              $
                760

              For
                year ended 12-31-2010

              $
                760

              For
                year ended 12-31-2011

              $
                760

    The
      weighted average useful lives of acquired intangibles related to vendor
      agreements and customer relationships are 20 years and 8.9 years, respectively.
      The weighted useful life of acquired other intangibles in total is 11.4
      years.

    Of
      the
      $15.1 million balance of goodwill at December 31, 2006, $13.8 million is
      expected to be deductible for tax purposes.

    Goodwill

    The
      changes in the carrying amount of goodwill for the year ended December 31,
      2006
      are as follows:

              Total

              Balance
                as of January 1, 2006

              $7,436

              Goodwill
                acquired during year

              14,690

              Impairment
                losses

              -

              Goodwill
                reclassified as other intangibles

              (7,002)

              Balance
                as of December 31, 2006

              $15,124

    3. All
      of
      the estimate of intangible assets related to the 2006 acquisitions relate to
      customer relationships. I estimated the weighted average useful life of these
      intangible assets to be seven years. These intangible assets and the related
      useful life are included in the example disclosure included in my response
      to
      comment number 2 above.

    4. Inventories

          4.

            The
              revised disclosure regarding inventories which will be included in
              future
              filings follows:

    The
      Company uses the LIFO method of inventory valuation for approximately 79% of
      its
      inventories. Remaining inventories, consisting primarily of used equipment,
      work
      in process, and products used to fabricate, repair and remanufacture customer
      specific pump packages, are accounted for using the FIFO method.

    9. Commitments
      and Contingencies

      5.
      DXP
      believes that losses related to the $20 million claim by a major energy company
      are not reasonably possible. In future filings the disclosure of this claim
      will
      include the following statement, ‘DXP currently believes that losses related to
      this claim are not reasonably possible.”

    Please
      contact me at 713-996-4897 if you have any questions regarding this letter
      or to
      confirm that the staff will have no further comments on our filing.

    Sincerely,

    Mac
      McConnell

    Senior
      Vice President & CFO