EXHIBIT 5.1

May 12, 1999


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

          RE:  Post-Effective   Amendment   No.   2  (the   "Post-Effective
               Amendment") to the  Registration  Statement filed on January
               21,  1999 on Form  S-8  (Registration  No.  333-70879)  (the
               "Registration  Statement")  for the  Dal-Tile  International
               Inc. 1990 Stock Option Plan (As Amended and  Restated)  (the
               "Plan").

Ladies and Gentlemen:

     This opinion is delivered in connection with the Post-Effective
Amendment to the Registration Statement for Dal-Tile International Inc., a
Delaware corporation (the "Company") under the Securities Act of 1933 (the
"Act"), for the purpose of registering an additional 2,750,000 shares of
common stock of the Company, par value $.01 per share (the "Common Stock")
issuable upon the exercise of stock options granted pursuant to the Plan.

     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 2,750,000 shares
of Common Stock to be registered pursuant to the Post-Effective Amendment
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 Post-Effective
Amendment and further consent to the inclusion of this opinion as Exhibit
5.1 to the Post-Effective Amendment. 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 Post-Effective Amendment 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