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                           September 22, 2022

       Gabriel Bruno
       Chief Financial Officer
       Lincoln Electric Holdings Inc.
       22801 St. Clair Avenue
       Cleveland, Ohio 44117

                                                        Re: Lincoln Electric
Holdings Inc.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2021
                                                            Filed February 18,
2022
                                                            File No. 000-01402

       Dear Mr. Bruno:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 22

   1.                                                   We note that you
identify Return on Invested Capital ("ROIC") as a key financial measure
                                                        on page 18 and a
non-GAAP measure on pages 22 and 26. You explain that "ROIC is
                                                        defined as rolling 12
months of Adjusted net income excluding tax-effected interest
                                                        income and expense
divided by invested capital."

                                                        However, you have not
provided the disclosures required by Item 10(e) of Regulation S-
                                                        K, pertaining to this
measure, such as the most directly comparable GAAP based measure
                                                        or a reconciliation
from that measure to your non-GAAP measure. Please submit the
                                                        revisions that you
proposed to comply with the aforementioned guidance.
 Gabriel Bruno
Lincoln Electric Holdings Inc.
September 22, 2022
Page 2
Financial Statements
Note 4 - Acquisitions, page F-16

2.       We note that you report several business acquisitions although have
not provided all of the
         information required by FASB ASC 805-10-50, to enable users of your
financial
         statements to evaluate the nature and financial effects of these
transactions.

         However, you report $156.1 million paid for acquisitions during 2021
on page F-8, which
         represented 42.8% of operating cash flows, and disclose that
acquisitions during 2021
         accounted for 15.2% and 24.3% of the change in revenues for your
International Welding
         and Harris Products Group reportable operating segments on page 20.

         Please expand your disclosures to more thoroughly describe each
acquisition, including
         specification of the amount and form of consideration, also the
acquisition date,
         percentage of interests acquired, and manner of accounting applied.

         Also disclose the amounts recognized in accounting for these
transactions, including
         acquisition-related costs, the line items in which those amounts are
recognized, as well as
         the amounts of revenues and earnings of the acquirees since the
acquisition date in the
         reporting period, and related pro forma information as if the
transactions had occurred as
         of the beginning of the comparable prior annual reporting period.

         As it appears that you have not reported non-cash investing and
financing activities
         pursuant to FASB ASC 230-10-50-3, please clarify whether there were no
such activities
         or whether you concluded that disclosure was not required due to an
assessment of
         materiality, in which case also provide us with details of the
amounts, related transactions,
         and the analyses underlying your view on materiality.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

      You may contact John Cannarella, Staff Accountant, at (202) 551-3337 or
Karl Hiller,
Branch Chief, at (202) 551-3686 with any questions.



FirstName LastNameGabriel Bruno                                Sincerely,
Comapany NameLincoln Electric Holdings Inc.
                                                               Division of
Corporation Finance
September 22, 2022 Page 2                                      Office of Energy
& Transportation
FirstName LastName