SecProbe.io

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Mail Stop 7010

      December 13, 2005

Via U.S. mail and facsimile

Mr. Maurice M. Taylor Jr.
President and Chief Executive Officer, Titan International, Inc.
2701 Spruce Street
Quincy, IL  62301

	RE:	Form 10-K for the fiscal year ended December 31, 2004
		Form 10-Q for the period ended September 30, 2005
			File No. 1-12936

Dear Mr. Taylor:

		We have reviewed these filings and have the following
comments.  If you disagree with a comment, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

General

1. Where a comment below requests additional disclosures or other
revisions to be made, please provide to us your intended
disclosure.
These revisions should be included in your future filings.

Properties, page 11

2. Specifically state whether each of your properties is owned or
leased.  In this regard, we suggest you present a table
summarizing
your owned and leased properties, and indicating whether such
facilities are active or idled.  See Item 102 of Regulation S-K
for
guidance.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Overview, page 14

3. In light of your facility consolidations, discuss your current
capacity utilization and whether you have any current plans to
increase or decrease your production capacity.  Also, discuss the
potential effects of these plans (if any) on your financial
results
with emphasis on any known trends or uncertainties.  See Item 303
(a)(3)(ii) of Regulation S-K.

Results of Operations, page 19

4. Please disclose the extent to which each business reason
discussed
for the changes between periods in your results of operations
contributed to the overall change in the various line items.  In
this
regard, we note that when discussing changes in the various line
items, you cite price increases, higher demand, higher sales
volume,
and facility consolidations.  In circumstances where there is more
than one business reason for the change, quantify the incremental
impact of each individual business reason discussed on the overall
change in the line item.  See Item 303 of Regulation S-K and SEC
Release 33-8350.

Contractual Obligations and Off-Balance Sheet Arrangements, page
29

5. Please revise your table of contractual obligations to include
estimated interest payments on your debt.  Because the table is
aimed
at increasing transparency of cash flow, we believe these payments
should be included in the table.  Please also disclose any
assumptions you made to derive these amounts.

Note 1.  Summary of significant accounting policies, page F-8

6. Please disclose the types of expenses that you include in the
cost
of sales line item and the types of expenses that you include in
the
selling, general and administrative expenses line item.  Please
also
tell us whether you include purchasing and receiving costs,
inspection costs, warehousing costs, internal transfer costs, and
the
other costs of your distribution network in the cost of sales line
item.  With the exception of warehousing costs, if you currently
exclude a portion of these costs from cost of sales, please
disclose:
?		in a footnote the line items that these excluded costs
are
included in and the amounts included in each line item for each
period presented, and
?	in MD&A that your gross profit margins may not be comparable
to
those of other entities, since some entities include all of the
costs
related to their distribution network in cost of sales and others
like you exclude a portion of them from gross profit margin,
including them instead in another line item, such as selling,
general
and administrative expenses.

Inventories, page F-8
7. You should use one inventory method for similar types of
inventories.  A mixture of methods should only be used for
different
types of inventories, particularly when there are valid business
reasons for doing so.  Please disclose which types of inventory
you
use each method for.  Please disclose whether you use both methods
for similar types of inventory.  If so, disclose your basis for
doing
this.  In a portion of these instances, this may be due to the
LIFO
method being used for similar types of inventory in countries that
permit the LIFO method and the FIFO method may be used in
countries
that do not permit the use of the LIFO method.  If this is the
case
for some of your inventory, please identify the foreign countries
with similar inventory categories to those you use the LIFO method
for in the U.S., and tell us separately for each country why you
do
not use the LIFO method for your inventories in that country.  If
you
are permitted to use the LIFO method in that country, tell us why
your selective use of LIFO for similar types of inventories is
appropriate.

Note 25.  Litigation

8. Please provide a description of the Dyneer legal matter as well
as
the disclosures required by paragraphs 9 and 10 of SFAS 5.

Form 10-Q for the Period Ended September 30, 2005

General

9. Please address the comments above in your interim filings as
well.

Note 7.  Restricted cash deposits, page 8

10. Please tell us how you determined it is not appropriate to
accrue
for the full judgment amount for the matter of Vehicular
Technologies
v. Titan Wheel in accordance with SFAS 5.

Note 14.  Income taxes, page 11

11. During the quarter ended March 31, 2005 you recorded a
provision
for income taxes of $1,245,000.  Subsequently you recorded income
tax
benefits of $434,000 during the quarter ended June 30, 2005 and
$811,000 during the quarter ended September 30, 2005.  Please tell
us
how you arrived at the amount of income tax benefit or provision
to
be recorded during each of the quarters in the nine month period
ended September 30, 2005.

*    *    *    *
		Please respond to these comments within 10 business
days,
or tell us when you will provide us with a response.  Please
provide
us with a supplemental response letter that keys your responses to
our comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* 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.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      If you have any questions regarding these comments, please
direct them to Marie Trimeloni, Staff Accountant, at (202) 551-
3734
or, in her absence, to Nudrat Salik, Review Accountant, at (202)
551-
3692.

							Sincerely,

							Rufus Decker
							Accounting Branch Chief

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Mr. Maurice M. Taylor Jr.
December 13, 2005
Page 4 of 4

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE

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