SecProbe.io

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

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010
December 19, 2007
 Via U.S. mail and facsimile

 Mr. Kent W. Hackamack Vice President of Finance and Chief Financial Officer Titan International, Inc.
2701 Spruce Street
Quincy, IL  62301
 RE: Form 10-K for the fiscal  year ended D ecember 31, 2006
File No. 1-12936

Dear Mr. Hackamack:    We have reviewed your 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.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with 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 re view 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, 2006

 General

1. Where a comment below requests additional disclosures or other revisions to be
made, please show us in your response wh at the revisions will look like.  These
revisions should be included in your future  filings, including your interim filings.

Mr. Kent W. Hackamack
Titan International, Inc.
December 19, 2007 Page 2    Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

 Results of Operations, page 20

2. We note your discussion of segment results beginning on page 22.  Please revise to
provide a more comprehensive analysis of segment operating results for each
segment, including a discussion of gr oss profit, and selling, general and
administrative expenses.  Please also consider including a table in your segment MD&A showing the operating results of each  segment, including corporate, that
reconciles to your cons olidated results.
 Corporate Expenses, page 23

3. It appears from your discussion on page F-29 that total corporate expenses amounted
to $39.2 million in 2005, not $24.0 million as disclosed on page 23.  Please revise your comparison of 2006 to 2005 by also discussing the Dyneer legal charge of $15.2 million that was recorded in 2005.
 Liquidity and Capital Resources, page 27

4. Please revise to provide a more robust anal ysis of the reasons for changes in your
operating, investing and financ ing cash flows.  Your revised discussions should not
only quantify the impact of th e line item(s) which contributed  most to the changes but
should also provide detailed explanations of the reasons for the fluctuations.
 Contractual Obligations, page 29

5. We note from your disclosures on page F-20 th at you are obligated to pay royalty fees
under a license agreement w ith The Goodyear Tire & Rubber Company.  It appears
that these fees may not be included in your  contractual obligati ons table on page 29.
If not already disclosed, pleas e revise to include these pa yments in your contractual
obligations table.  Please also revise your contractual obligations to disclose the
assumptions used to calculated paym ents required by this agreement.

Mr. Kent W. Hackamack
Titan International, Inc.
December 19, 2007 Page 3    Consolidated Financial Statements

 Consolidated Statements of Cash Flows, page F-7

6. We note the line item titled “other, net” wh ich constituted approximately 80% of your
net cash used for operating activities fo r the year ended December 31, 2006.  It
appears that you may be netti ng cash flows related to other assets and other liabilities
in your operating activities, which is not a ppropriate.  Please revise to present cash
flows related to deferred charges and other assets separate from those related to
deferred credits and other liabilities.  Please also revise to include separate line items
for items that are individually significant to net cash used in operating activities.  See
SFAS 95.
 Note 2 – Acquisitions, page F-13

7. Please revise to disclose the conditions under which the subsequent payment of $9
million is due and the estimated timing of this payment.  If not already disclosed, please also revise to include  this payment in your cont ractual obligations table on
page 29.
 Note 8 – Investment in Titan Europe, page F-16

8. Please confirm to us that you do not have the ability to exercise significant influence
over Titan Europe Plc through means other than 20% ownership.  Indicators of the
ability to exercise significant influen ce include representation on the board of
directors, participation in the policy making process, material intercompany
transactions, and/or Titan’s Europe’s depende nce on Titan International, Inc.  Refer to
paragraph 17 of APB 18.

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

Mr. Kent W. Hackamack
Titan International, Inc. December 19, 2007 Page 4
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 info rmed decision.  Since the company and its
management are in possession of all facts re lating 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 comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance 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 Lisa
Haynes, Staff Accountant, at (202) 551-3424 or, in her absen ce, to the undersigned at
(202) 551-3769.

        S i n c e r e l y ,              R u f u s  D e c k e r          A c c o u n t i n g  B r a n c h  C h i e f