SEC Comment Letter for TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Aug 29, 2012
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: Aug. 29, 2012 · CIK: 0000899751 · Accession: 0000000000-12-047016
AI Filing Summary & Sentiment
Referenced dates: August 15, 2012
Letter
August 29 , 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 24 , 2012 File No. 1-12936
Dear Mr. Reitz :
We have reviewed yo ur response letter dated August 24 , 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 15, 2012. As previously requested, please provide the actual, specific terms of the original supply agreement. For example, tell us the minimum number and maximum number of non - farm tires to be supplied to Goodyear that was stipulated in the agreement. In addition, pleas e provide us with the calculations you used to determine the original value of liability recorded in connection with this agreement. If the liability was not based on the
Mr. Paul G. Reitz Titan International, Inc. August 29, 2012 Page 2
minimum amount of non -farm tires to be supplied to Goodyear as set forth in the agreement, please provide support for the number of tires you assumed you would sell to 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/ John Cash, for
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August 29 , 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 24 , 2012 File No. 1-12936 Dear Mr. Reitz : We have reviewed yo ur response letter dated August 24 , 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 15, 2012. As previously requested, please provide the actual, specific terms of the original supply agreement. For example, tell us the minimum number and maximum number of non - farm tires to be supplied to Goodyear that was stipulated in the agreement. In addition, pleas e provide us with the calculations you used to determine the original value of liability recorded in connection with this agreement. If the liability was not based on the Mr. Paul G. Reitz Titan International, Inc. August 29, 2012 Page 2 minimum amount of non -farm tires to be supplied to Goodyear as set forth in the agreement, please provide support for the number of tires you assumed you would sell to 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/ John Cash, for Rufus Decker Accounting Branch Chief