SecProbe.io

Mailstop 4628
March 9, 2016

Via E -mail
Maurice M. Taylor Jr.
Chairman and Chief Executive Officer
Titan International, Inc.
2701 Spruce Street
Quincy, IL 62301

Re: Titan International, Inc.
 Form 10 -K for the Fiscal Year Ended December 31, 2015
Filed February 24, 2016
File No. 1 -12936

Dear Mr. Taylor:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments, we ask you to provide us with information so we may better
understand your disclosure.

Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  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.

General

1. We note a press release dated November 6, 2015 on your website, announcing that you
entered into a licen sing agreement with The Goodyear Tire & Rubber Company to
distribute and sell Goodyear -brand farm tires in countries including Sudan and Syria.
Sudan and Syria are designated by the State Department as state sponsors of terrorism,
and are subject to U.S.  economic sanctions and export controls.  Your Form 10 -K does
not include disclosure about contacts with Sudan or Syria.  Please describe to us the
nature and extent of any past, current and anticipated contacts with Sudan and Syria,
whether through direct  or indirect arrangements.  You should describe any products,
services or technology you have provided into Sudan and Syria, directly or indirectly, and
any agreements, commercial arrangements or other contacts you have had with the
governments of those co untries or entities they control.

Maurice M. Taylor Jr.
Titan International, Inc.
March 9 , 2016
Page 2

 2. Please discuss the materiality of any contacts with Sudan and Syria you describe in
response to the comment above, and whether the contacts constitute a material
investment risk for your security holders.   You should addr ess materiality in quantitative
terms, including the approximate dollar amounts of any revenues, assets and liabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.   Also, address materiality in terms o f qualitative factors that a reasonable investor
would deem important in making an investment decision, including the potential impact
of corporate activities upon a company’s reputation and share value.   Various state and
municipal governments, universiti es and other investors have proposed or adopted
divestment or similar initiatives regarding investment in companies that do business with
U.S.-designated state sponsors of terrorism.   You should address the potential impact of
the investor sentiment eviden ced by such actions directed toward companies that have
operations associated with Sudan and Syria.

We urge all 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 applicable 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.

 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 filing; 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 Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202)
551-3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Pamela Long
  Assistant Director
 Division of Corporation Finance