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      TITAN
        INTERNATIONAL, INC.

      December
        27, 2005

      Rufus
        Decker

      Accounting
        Branch Chief

      United
        States

      Securities
        and Exchange Commission

      Washington,
        D.C. 20549-7010

      RE:  Titan
        International, Inc.

          Form
        10-K for
        the fiscal year ended December 31, 2004

          Forms
        10-Q
        for the period ended September 30, 2005

          File
        No.
        1-12936

      Dear
        Mr.
        Decker,

      We
        have
        received your faxed letter dated December 13, 2005, regarding the review
        of the
        above mentioned filings of Titan International, Inc. (the Company). Please
        see
        the attached Exhibit A for the Company’s responses to your letter. If you have
        any questions, please advise.

      Sincerely,

      /s/
        Maurice M. Taylor Jr.

      Maurice
        M. Taylor Jr.

      Chief
        Executive Officer

      EXHIBIT
        A
        - COMMENTS & RESPONES

      FORM
        10-K FOR THE YEAR ENDED DECEMBER 31, 2004

      General

              1.

                Where
                  a comment below requests additional disclosures or other revisions
                  to be
                  made, please provide to us your intended disclosure. These revisions
                  should be included in your filings.

      Response
        to comment 1:

      Titan
        International, Inc. (Titan or the Company) has provided intended disclosure
        for
        comments below which request additional disclosure or other revisions to
        be
        made. These revisions will be included in the future filings of the
        Company.

      Properties,
        page 11

              2.

                Specifically
                  state whether each of your properties is owned or leased. In this
                  regard,
                  we suggest you present a table summarizing your owned and leased
                  properties, and indicating whether such facilities are active or
                  idle. See
                  Item 102 of Regulation S-K for
                  guidance.

      Response
        to comment 2:

      In
        Part
        I, Item 2, the Company’s property information was listed in paragraph form. The
        property information in table format for December 31, 2004, would be as
        follows:

                Approximate
                  square footage

                Location

                Owned

                Leased

                Use

                Segment

                Brownsville,
                  TX

                993,000

                Manufacturing,
                  distribution

                Idled

                Cartersville,
                  GA

                169,000

                Distribution

                All
                  segments

                Des
                  Moines, IA

                2,207,000

                Manufacturing,
                  distribution

                All
                  segments

                Dublin,
                  GA

                20,000

                Distribution

                All
                  segments

                Elko,
                  NV

                4,000

                Distribution

                Earthmoving/Construction

                Greenwood,
                  SC

                110,000

                Manufacturing

                Idled

                Natchez,
                  MS

                1,203,000

                Manufacturing

                Idled

                Quincy,
                  IL

                1,134,000

                Administrative,
                  manufacturing

                All
                  segments

                Saltville,
                  VA

                14,000

                245,000

                Manufacturing

                Earthmoving/Construction

                Walcott,
                  IA

                378,000

                Manufacturing

                Idled

      In
        future
        Form 10-K filings, the Company will provide its property information in a
        table
        format as shown above.

          A
            -
            1

      Management’s
        Discussion and Analysis of Financial Condition and Results of
        Operations

      Overview,
        page 14

              3.

                In
                  light of your facility consolidations, discuss your current capacity
                  utilization and whether you have any current plans to increase
                  or decrease
                  your production capacity. Also, discuss the potential effects of
                  these
                  plans (if any) on your financial results with emphasis on any known
                  trends
                  or uncertainties. See Item 303 (a)(3)(ii) of Regulation
                  S-K.

      Response
        to comment 3:

      In
        Part
        I, Item 2, the Company provided the following disclosure, “Management believes
        that the Company has sufficient capacity to meet current market demand.” This
        statement can be expanded to include the Company has sufficient capacity
        to meet
        current market demand with the facilities that are currently active and the
        Company has no current plans to reopen the idled facilities. With the Company
        having no current plans on capacity changes, there are no related financial
        impacts. In future Form 10-K filings, the Company will provide a statement
        on
        production capacity along with additional information regarding its plans,
        if
        any, to reopen the idled facilities, when applicable.

      The
        Company may at times make strategic acquisitions; these acquisitions are
        not
        made, at this time, to increase capacity to meet current demand, but to expand
        the Company’s business. Potential acquisitions involve a high degree of
        uncertainty and confidentiality. The Company reports potential acquisitions
        to
        stockholders at the appropriate time. On February 28, 2005, Titan Tire
        Corporation, a subsidiary of Titan International, Inc., entered into a
        definitive agreement to purchase The Goodyear Tire & Rubber Company’s North
        American farm tire business. The Company filed a Form 8-K on the same day,
        February 28, 2005, announcing this agreement. This agreement has not been
        finalized at this time. However, this transaction is expected to close on
        December 28, 2005.

      Results
        of Operations, page 19

              4.

                Please
                  disclose the extent to which each business reason discussed for
                  the
                  changes between periods in your results of operations contributed
                  to the
                  overall change in the various line items. In this regard, we note
                  that
                  when discussing changes in the various line items, you cite price
                  increases, higher demand, higher sales volume, and facility
                  consolidations. In circumstances where there is more than one business
                  reason for the change, quantify the incremental impact of each
                  individual
                  business reason discussed on the overall change in the line item.
                  See Item
                  303 of regulation S-K and SEC Release
                  33-8350.

      Response
        to comment 4:

      The
        Company’s Form 10-K includes the following in the Net
        Sales
        paragraph on page 19, “The increase in net sales on a comparative basis was
        $113.2 million. Of this amount, approximately 26% was due to price increases
        related to higher raw material costs being passed on to customers. The remaining
        amount was primarily attributed to higher demand from the Company’s agricultural
        segment.” When the Company cites certain business reasons, that information will
        be provided, when applicable, in future filings. The net sales increase of
        $113.2 million was comprised of $29.6 million of steel surcharges and the
        remaining $83.6 million was primarily due to higher sales volume demand.

      For
        the
        2004 Form 10-K, information regarding your comment would be as follows. For
        the
Gross
        Profit section,
        the gross profit increase of $49.8 million was comprised of $8.4 million
        as the
        result of facility consolidations and the remaining $41.4 million increase
        in
        gross profit was a result of the higher sales volume demand.

      For
        the
Income
        from Operations section,
        income increased $49.5 million. This increase is comprised of the gross profit
        increase of $49.8 million offset by a $0.3 million increase in administrative
        expenses. Administrative expenses were negatively affected by goodwill
        impairment charge of $3.0 million and idled asset depreciation charge of
        $5.3
        million. These charges were nearly offset by the $8.0 million reduction in
        selling, general and administrative and research and development expenses
        of
        which $7.5 million related to the April 2004 sale of Titan Europe.

      For
        the
Interest
        Expense
        section,
        interest expense was reduced by $4.0 million. The Company’s average debt
        balances in 2004 were approximately $46 million lower when compared to 2003
        resulting in a reduction of interest expense of $3.4 million. The Company’s
        average interest rates in 2004 were 7.30%, which was approximately 25 basis
        points lower than the average 2003 interest rates resulting in an interest
        savings of $0.6 million.

          A
            -
            2

      Contractual
        Obligations and Off-Balance Sheet Arrangements, page 29

              5.

                Please
                  revise your table of contractual obligations to include estimated
                  interest
                  payments on your debt. Because the table is aimed at increasing
                  transparency of cash flow, we believe these payments should be
                  included in
                  the table. Please also disclose any assumptions you made to derive
                  these
                  amounts.

      Response
        to comment 5:

      The
        Company will revise the contractual obligations table in future Form 10-K
        filings to include estimated interest payments on debt. The table for December
        31, 2004, would include the following estimated interest payments
        information:

                Payments
                  due by period

                Contractual
                  Obligations

                Total

                Less
                  than 1
                  year

                1-3
                  years

                3-5
                  years

                More
                  than 5
                  years

                Long-term
                  debt - Estimated interest payments (a)

                35,627

                8,922

                16,724

                9,949

                32

              (a)

                Estimated
                  interest payments are based on the Company’s year-end 2004 debt balances
                  and maturities including interest rates that are anticipated to
                  remain at
                  the current rates. The Company’s actual debt balances and interest rates
                  may fluctuate in the future. Therefore, actual interest payments
                  may vary
                  from those payments detailed in the above
                  table.

      Note
        1. Summary of significant accounting policies, page F-8

              6.

                Please
                  disclose the types of expenses that you include in cost of sales
                  line item
                  and the types of expenses that you include in the selling, general
                  and
                  administrative expenses line item. Please also tell us whether
                  you include
                  purchasing and receiving costs, inspection costs, warehousing costs,
                  internal transfer costs, and the other costs of your distribution
                  network
                  in the cost of sales line item. With the exception of warehousing
                  costs,
                  if you currently exclude a portion of these costs from cost of
                  sales,
                  please disclose:

              ·

                In
                  a footnote the line items that these excluded costs are included
                  in and
                  the amounts included in each line item for each period presented,
                  and

              ·

                In
                  MD&A that your gross profit margins may not be comparable to those
                  of
                  other entities, since some entities include all of the costs related
                  to
                  their distribution network in cost of sales and others like you
                  exclude a
                  portion of them from gross profit margin, including them instead
                  in
                  another line item, such as selling, general and administrative
                  expenses.

      Response
        to comment 6:

      The
        bulleted items in comment 6 are not applicable to the Company as the Company
        includes all purchasing, receiving, inspection, internal transfer, and related
        distribution costs in the cost of sales line. In future Form 10-K filings,
        the
        Company will include disclosures similar to the following in the summary
        of
        significant accounting policies:

      Cost
        of sales: Cost
        of
        sales is comprised primarily of direct materials and supplies consumed in
        the
        manufacturing of the Company’s products, as well as manufacturing labor,
        depreciation expense and overhead expense necessary to acquire and convert
        the
        purchased materials and supplies into a finished product. Cost of sales also
        includes all purchasing, receiving, inspection, internal transfers, and related
        distribution costs.

      Selling,
        general and administrative expense: Selling,
        general and administrative expense is comprised primarily of sales commissions,
        marketing expense, selling and administrative wages, management information
        system costs, legal fees, bank charges, audit fees, depreciation and
        amortization expense on non-manufacturing assets, and other administrative
        items.

          A
            -
            3

      Inventories,
        page F-8

              7.

                You
                  should use one inventory method for similar types of inventories.
                  A
                  mixture of methods should only be used for different types of inventories,
                  particularly when there are valid business reasons for doing so.
                  Please
                  disclose which types of inventory you use each method for. Please
                  disclose
                  whether you use both methods for similar types of inventory. If
                  so,
                  disclose your basis for doing this. In a