SecProbe.io

August  28, 2015

Mail Stop 4631

Via E -mail
Mr. John Hrudicka
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, 2014
Filed February 26, 2015
  File No. 1 -12936

Dear Mr. Hrudicka :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respon d.  If you do not believe our
comments apply to your facts and circumstances, please  tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 10 -K for the Year Ended December 31, 2014

General

1. In your Form 8 -K filed on February 25, 2015, you indicate that you removed
approximately 2,000 employees plus numerous temporary workers during 2014, and that
the cost of the removal was recognized in 2014.  It is not clear to us where this
inform ation is disclosed in your Form 10 -K.  Please advise.  Also, please help us
understand how you complied with the disclosure requirements of ASC 420 -10-50-1.

Mr. John Hru dicka
Titan International , Inc.
August  28, 2015
Page 2

Item 7 – Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Critical Accounting Estimates – Product Warranties, page 24

2. Please revise future filings to disclose the amount of warranty expense you recorded
during each period presented and to discuss how you determined those amounts, and
address the specific facts and circumstances that have led to material declines in your
expense in the most recent year  and current interim periods.

Results of Operations, page 25

3. We note material negative trends in consolidated and certain segment sales during 2014
and the current interim periods.  Please revise future annual and quarter ly filings to more
fully disclose and discuss the reasons for the negative trends and address the extent to
which they relate to you or your industry by disclosing an estimate of your market share
during each period presented.  In addition, please revise f uture annual and quarterly
filings to separately disclose and discuss changes in OEM sales and after -market sales, to
the extent material, and to address the impact that percentage changes in such sales
relative to total sales have on your results of opera tions.

Item 15 – Exhibits and Financial Statement Schedules

Note 2. Mining Asset Impairment and Inventory Writedown, page F -12

4. We note you recorded an asset impairment and inventory writedown of $23.2 million and
$16.7 million, respectively.  It appear s to us that y our related disclosures may not provide
investors with sufficient information about management’s insights and assumptions with
regard to how you determined these amounts and how you assessed the recoverability of
any remaining asset balances.   In future filings, please provide qualitative and
quantitative descriptions of the key assumptions you use to determine material
impairments you record and provide a related sensitivity analysis.  Please also expand
your disclosures in future filings to address the level at which you assess long -lived assets
for impairment and to provide information regarding known trends, uncertainties or other
factors that could reasonably likely result in additional material impairmen ts in future
periods.

We urge al l persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applica ble Exchange Act rules require.   Since the company and its  management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

Mr. John Hru dicka
Titan International , Inc.
August  28, 2015
Page 3

In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the fi ling; 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.

You may contact Jeffrey Gordon, Staff Accountant, at (202) 551 -3866 or Anne
McConnell, Staff Accountant , at (202) 551 -3709 with any questions.

 Sincerely,

 /s/ John Cash

 John Cash
 Accounting Branch Chief
Office of Manufacturing and
Construction