SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                                             March 26, 2010
 Kent W. Hackamack Vice President of Finance and Treasurer Titan International, Inc. 2701 Spruce Street Quincy, Illinois 62301
 RE: Titan International, Inc.
Form 10-K for the Year Ended December 31, 2009
File No. 1-12936

Dear Mr. Hackamack:
  We have reviewed your response letter filed on March 19, 2010 and have the following
comments.  Where indicated, we think you should re vise your disclosures in response to these
comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed as necess ary in your explanation.
Please understand that the purpose of  our review process is to a ssist you in your compliance with
the applicable disclosure requirements and to enhan ce 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 phone numbers listed
below.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2009

 General

1. In response to comment one of our letter da ted February 24, 2010, you state that the main
term that would be important to an investor with respect to the Goodyear license agreement
“includes the financial impact on Titan and the te rm (i.e. duration) of the contract.”  You
also argue that information about the annual roya lty expense to Titan is public information;
however, your analysis does not address the fi nancial impact that the sale of Goodyear
branded tires has had and continues to have on your business.  Please tell us what that
financial impact has been and the role that it played in your determination of whether your
business depends to a material extent on the licen se agreement.  Please be advised that if the
license agreement is considered to be material  pursuant to the criteria set forth in Item
601(b)(10)(ii)(B) of Regulation S- K, you may file a redacted vers ion of this agreement with
your next periodic report and simultaneously  request confidential treatment of the

Mr. Kent W. Hackamack
March 26, 2010 Page 2
information you seek to keep confidential.  Fo r additional guidance, please see comment one
of our letter dated January 20, 2010.
2. In response to comment two of our letter date d February 24, 2010 you st ate that one of the
reasons that the agreement with John Deere is not material is  that in prior years you have
done business with this signi ficant customer (accounting for 24% of your 2009 sales)
without the presence of a cont ract.  Your argument fails to  address, however, why since
2004 the business has been conducted pursuant to  a written arrangement, which term has
been extended, rather than continue operating wi thout the presence of a written contract.  In
addition, your argument that the 22% of  your John Deere business for 2008 was a
combination of “all the John D eere contracts” (of which you discuss only two) does not
reflect the fact that your busine ss is not a diversified business, the sole focus of which is the
sale of tires.  In the third paragraph of your response to our  prior comment two you also state
that you have had to replace OEM’s with busin ess from other customers, giving you reason
to believe that you are not dependent on any one customer.  Such statement appears to
contradict your risk factor “The company’s customer base is relatively concentrated” on
page 12 of your latest annual report.  In light of these facts, it appears that you are
substantially dependent upon th e two contracts with John Deer e, such that the contracts
should be filed as exhibits pursuant to Item 601(b)(10)(ii)(B) of Regulation S-K.  Please
advise or otherwise file thes e contracts as exhibits.

*    *    *    *

  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 response letter that keys  your responses to our
comments and provides any requested information.  De tailed letters greatly f acilitate our review.
Please file your response on EDGAR as a corresponde nce file.  Please underst and that we may have
additional comments after reviewin g your responses to our comments.

You may contact Era Anagnosti, Attorney, at (202) 551-3369 or, in her absence, Pamela
Long, Assistant Director, at (202) 551-3760 if you have any questions regarding legal matters.
Please contact Ernest Greene, Staff Accountant,  at (202) 551-3733 or, in his absence, the
undersigned at (202) 551-3769 if you have quest ions regarding comments on the financial
statements and related matters.          Sincerely,             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