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SEC Comment Letter for TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Sep 20, 2012

TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: Sept. 20, 2012 · CIK: 0000899751 · Accession: 0000000000-12-051599

AI Filing Summary & Sentiment

Date
December 31, 2011
Author
/s/ Rufus Decker
Form
UPLOAD
Company
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)

Letter

September 20 , 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 File No. 1 -12936

Dear Mr. Reitz:

We have completed our review of your filings. We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing s and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. We urge all pe rsons who are responsible for the accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Rufus Decker

Show Raw Text
September 20 , 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
  File No. 1 -12936

Dear Mr. Reitz:

We have completed our review of your filings.  We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.  We urge all pe rsons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Rufus Decker

 Rufus Decker
Accounting B ranch Chief