SEC Comment Letter for TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Aug 15, 2012
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: Aug. 15, 2012 · CIK: 0000899751 · Accession: 0000000000-12-044312
AI Filing Summary & Sentiment
Referenced dates: August 2, 2012
Letter
August 15 , 2012 Via E -mail Mr. Paul G. Reitz Chief Financial Officer Titan International, Inc. 2701 Spruce Street Quincy, IL 62301
RE: Titan International, Inc. Form 10 -K for the Year ended December 31, 2011 Filed February 23, 2012 Form 10 -Q for the Quarter ended June 30 , 2012 Filed July 26, 2012 Response dated August 8 , 2012 File No. 1-12936
Dear Mr. Reitz :
We have reviewed yo ur response letter dated August 8 , 2012 and have the following additional comment . In our comment, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advisi ng us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we m ay have additional comments.
Form 10 -Q for the Quarter Ended June 30, 2012
Item 1 – Financial Statements
Note 14 – Supply Agreement Termination Income, page 13
1. We note your response to prior comment one from our letter dated August 2, 2012 and have the following additional comments: As previously requested, please provide the terms of the original supply agreement. Clarify whether there was a minimum number of non -farm tires you were required to provide to Goodyear. With reference to the terms of th e supply agreement, please tell us
Mr. Paul G. Reitz Titan International, Inc. August 15, 2012 Page 2
how you determined the original value of liability recorded in connection with this agreement. Please clarify whether there is a minimum number of non -farm tires that the Company must sell in order to fulfill its obligati ons under the new royalty agreement with Goodyear.
You may contact Jeffrey Gordon, Staff Accountant, at (202) 551 -3866 or, in his absence, Jeanne Baker , Assistant Chief Accountant, at (202) 551 -3691 if you have questions regarding this comment .
Sincerely,
/s/ Rufus Decker
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August 15 , 2012 Via E -mail Mr. Paul G. Reitz Chief Financial Officer Titan International, Inc. 2701 Spruce Street Quincy, IL 62301 RE: Titan International, Inc. Form 10 -K for the Year ended December 31, 2011 Filed February 23, 2012 Form 10 -Q for the Quarter ended June 30 , 2012 Filed July 26, 2012 Response dated August 8 , 2012 File No. 1-12936 Dear Mr. Reitz : We have reviewed yo ur response letter dated August 8 , 2012 and have the following additional comment . In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advisi ng us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we m ay have additional comments. Form 10 -Q for the Quarter Ended June 30, 2012 Item 1 – Financial Statements Note 14 – Supply Agreement Termination Income, page 13 1. We note your response to prior comment one from our letter dated August 2, 2012 and have the following additional comments: As previously requested, please provide the terms of the original supply agreement. Clarify whether there was a minimum number of non -farm tires you were required to provide to Goodyear. With reference to the terms of th e supply agreement, please tell us Mr. Paul G. Reitz Titan International, Inc. August 15, 2012 Page 2 how you determined the original value of liability recorded in connection with this agreement. Please clarify whether there is a minimum number of non -farm tires that the Company must sell in order to fulfill its obligati ons under the new royalty agreement with Goodyear. You may contact Jeffrey Gordon, Staff Accountant, at (202) 551 -3866 or, in his absence, Jeanne Baker , Assistant Chief Accountant, at (202) 551 -3691 if you have questions regarding this comment . Sincerely, /s/ Rufus Decker Rufus Decker Accounting Branch Chief