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SEC Comment Letter for TEREX CORP (TEX) (CIK 0000097216) (TEX) — Jan 9, 2013

TEREX CORP (TEX) (CIK 0000097216)
Date: Jan. 9, 2013 · CIK: 0000097216 · Accession: 0000000000-13-001395

Regulatory Compliance Financial Reporting Internal Controls

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Confidence
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Reasoning

Referenced dates: November 20, 2012

Date
January 9, 2013
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
TEREX CORP (TEX) (CIK 0000097216)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE January 9, 2013 Via E -mail Ronald M. DeFeo Chairman and Chief Executive Officer Terex Corporation 200 Nyala Farm Road Westport, Connecticut 06880

Re: Terex Corporation Form 10 -K for the Fiscal Year Ended December 31, 2011 Filed February 29, 2012 File No. 1 -10702

Dear Mr. DeFeo:

We refer you to our comment letters dated November 20, 2012 and December 6, 2012, regarding business contacts with Cuba, Iran, Sudan, and Syria. We have completed our review of this subject matter. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may no t assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
       DIVISION OF
CORPORATION FINANCE

January 9, 2013

Via E -mail
Ronald M. DeFeo
Chairman and Chief Executive Officer
Terex Corporation
200 Nyala Farm Road
Westport, Connecticut 06880

 Re: Terex Corporation
  Form 10 -K for the Fiscal Year Ended December 31, 2011
  Filed February 29, 2012
  File No. 1 -10702

Dear Mr. DeFeo:

We refer you to our comment letters dated November 20, 2012 and December 6, 2012,
regarding business contacts with Cuba, Iran, Sudan, and Syria.  We  have completed our review
of this subject matter.  We remind you that our comments or changes to disclosure in response to
our comments do not foreclose the Commission from taking any action with respect to the
company or the filing and the company may no t assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal securities laws of the
United States.  We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable rules require.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk
cc:  Amanda Ravitz
  Assistant Directo r
 Division of Corporation Finance