EXHIBIT 5.1

March 30, 1999


Dal-Tile International
7834 C.F. Hawn Freeway
Dallas, TX  75217

          RE:  Registration  Statement  on Form S-8 for Stock  Appreciation
               Rights  (the  "SARs")  granted  to  Jacques  R.  Sardas,  W.
               Christopher  Wellborn,  David F. Finnigan,  Dan L. Cooke and
               Marc S. Powell

Ladies and Gentlemen:

     This opinion is delivered in connection with the registration by
Dal-Tile International Inc., a Delaware corporation (the "Company"), on
Form S-8 (the "Registration Statement"), under the Securities Act of 1933
(the "Act"), as amended, of 679,933 shares of common stock of the Company,
par value $.01 per share (the "Common Stock") which may be issued upon the
exercise of SARs granted on October 10, 1997, as amended on February 20,
1998.

     In arriving at this opinion, I have examined such corporate
instruments, documents, statements and records of the Company, and I have
examined such statutes and regulations and have conducted such legal
analysis, as I have deemed relevant, necessary and appropriate for the
purposes of this opinion. I have assumed the genuineness of all signatures
and the authenticity of all documents submitted to me as originals, the
conformity to original documents of all the documents submitted to me as
certified or photostatic copies, and the authenticity of the originals of
such latter documents. I also have assumed that any future changes to the
terms and conditions of the Plan will be duly authorized by the Company and
will comply with all applicable laws.

     Based on the foregoing, I am of the opinion that the 679,933 shares of
Common Stock which may be issued pursuant to the Registration Statement
have been duly authorized and, when issued and delivered by the Company in
accordance with the terms and conditions of the Plan, will be validly
issued, fully paid and nonassessable securities of the Company.

     I hereby consent to the reference to my name in the Registration
Statement and further consent to the inclusion of this opinion as Exhibit
5.1 to the Registration Statement. In giving this consent, I do not hereby
admit that I am in the category of persons whose consent is required under
Section 7 of the Act or the rules and regulations of the Securities and
Exchange Commission.

     The opinion expressed herein is solely for your benefit in connection
with the Registration Statement and may not be relied on in any manner or
for any purpose by any other person or entity and may not be quoted in
whole or in part without my prior written consent.

                                    Very truly yours,

                                     /s/ Mark A. Solls
                                    ---------------------------------
                                    Mark A. Solls
                                    Vice President, General Counsel
                                    and Secretary