SEC Comment Letter for TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — May 13, 2010

TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: May 13, 2010 · CIK: 0000899751 · Accession: 0000000000-10-026833

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AI Filing Summary & Sentiment

Date

May 13, 2010

Author

Accounting Branch Chief

Form

UPLOAD

Company

TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE VIA FACSIMILE AND U.S. MAIL May 13, 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, 2008 Form 10-K for the Year Ended December 31, 2009 Form 10-Q for the Period Ended March 31, 2010 File No. 1-12936

Dear Mr. Hackamack:

We have completed our review of your Fo rm 10-K and related filings and have no further comments at this time. If you have any further questions regardi ng our review of legal or disclosure matters in your filings, pleas e direct them to Era Anagnos ti, Attorney, at (202) 551-3369 or, in her absence, Pamela Long, Assistan t Director, at (202) 551-3760. Please contact Ernest Greene, Staff Accountan t, at (202) 551-3733 or, in hi s absence, the undersigned at (202) 551-3769 if you have questions regarding our review of the financial statements and related matters.

Sincerely, R u f u s D e c k e r
Accounting Branch Chief

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

       DIVISION OF
CORPORATION FINANCE

VIA FACSIMILE AND U.S. MAIL

                                                                             May 13, 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, 2008
Form 10-K for the Year Ended December 31, 2009
Form 10-Q for the Period Ended March 31, 2010 File No. 1-12936

Dear Mr. Hackamack:

We have completed our review of your Fo rm 10-K and related filings and have no
further comments at this time.
If you have any further questions regardi ng our review of legal or disclosure
matters in your filings, pleas e direct them to Era Anagnos ti, Attorney, at (202) 551-3369
or, in her absence, Pamela Long, Assistan t Director, at (202) 551-3760.  Please contact
Ernest Greene, Staff Accountan t, at (202) 551-3733 or, in hi s absence, the undersigned at
(202) 551-3769 if you have questions regarding our review of the financial statements
and related matters.

  Sincerely,            R u f u s  D e c k e r
       Accounting Branch Chief

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