SEC Comment Letter for TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Jul 5, 2013
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: July 5, 2013 · CIK: 0000899751 · Accession: 0000000000-13-036660
AI Filing Summary & Sentiment
Letter
July 5, 2013 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, 2012 Filed February 27, 2013 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 persons 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
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July 5, 2013 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, 2012 Filed February 27, 2013 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 persons 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 Branch Chief