                                                                Exhibit 5.1

October 25, 2001

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

          RE:  Registration statement on Form S-8 (the "Registration
               Statement") for the Dal-Tile International Inc. 1990 Stock
               Option Plan, as amended and restated (also known as the 2000
               Amended and Restated Stock Option Plan)(the "Plan").

Ladies and Gentlemen:

     This opinion is delivered in connection with 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 12,056,619 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 12,056,619 shares
of Common Stock to be registered 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

