SEC Comment Letter for TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Mar 18, 2016
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: March 18, 2016 · CIK: 0000899751 · Accession: 0000000000-16-068935
AI Filing Summary & Sentiment
Referenced dates: March 9, 2016
Letter
Mailstop 4628 March 18, 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 December 31, 2015 Filed February 25, 2015 File No. 1 -12936
Dear Mr. Taylor:
We refer you to our comment letter dated March 9, 2016, regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. 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 and the company may not asse rt 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 to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.
Sincerely,
/s/ Cecilia Blye
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Mailstop 4628 March 18, 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 December 31, 2015 Filed February 25, 2015 File No. 1 -12936 Dear Mr. Taylor: We refer you to our comment letter dated March 9, 2016, regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. 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 and the company may not asse rt 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 to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require. Sincerely, /s/ Cecilia Blye Cecilia Blye, Chief Office of Global Security Risk cc: Pamela Long Assistant Director Division of Corporation Fina nce