SecProbe.io

Mail Stop 3030
June 2 2, 2016

Via E -mail
Kevin P. Bradley
Senior Vice President and Chief Financial Officer
Terex Corporation
200 Nyala Farm Road
Westport, Connecticut  06880

Re: Terex Corporation
 Form 10 -K for the Fiscal Year Ended December 31, 2015
 Filed February 22, 2016
 Form 8 -K filed  April 26, 2016
 File No. 001-10702

Dear  Mr. Bradley :

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

Please respond to th is comment within ten business days by providing the requested
informatio n or advise us as soon as possible when you will respond.  If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to th is comment, we may have additional comments.

Form 8 -K filed April 26, 2016

Exhibit 99.1

1. We note that you present a non -GAAP measure titled “as adjusted basis loss from
continuing operations” but you have not provided the required reconciliations to the most
directly comparable GAAP meas ure as well as the other disclosures required by Item
10(e)(1)(i) of Regulation S -K.  Please confirm that in future filings you will revise your
presentations of non -GAAP measures to comply fully with that guidance.

We urge all persons who are responsibl e 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 Exchange Act rules require.   Since the company and its management are
in possessio n of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Kevin P. Bradley
Terex Corporation
June 2 2, 2016
Page 2

  In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not  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.

You may contact Tara Harkins  at (202) 551 -3639, or Kate Tillan, Assistant Chief
Accountant, at (202) 55 1-3604 with any questions.  You may also reach me at (202) 551 -3671.

Sincerely,

 /s/ Kate Tillan for

Martin James
Senior Assistant Chief Accountant
        Office of Electronics and Machinery