Correspondence 0000899751-24-000103 from TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI)
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: Dec. 19, 2024 · CIK: 0000899751 · Accession: 0000899751-24-000103
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File numbers found in text: 333-282964
Letter
VIA EDGAR Division of Corporation Finance Office of Manufacturing Registration Statement on Form S-3 Filed November 1, 2024 File No. 333-282964 REQUEST FOR ACCELERATION OF EFFECTIVENESS
Dear Messrs. Ewing and Ingram:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Titan International, Inc., a Delaware corporation (the “Company,” “we,” “our” or “us”), hereby requests that the effectiveness of the above-referenced Registration Statement on Form S-3 (File No. 333-282964) (the “Registration Statement”) be accelerated to, and that the Registration Statement become effective at, 1 p.m. Eastern Time on December 20, 2024, or as soon thereafter as practicable. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.
If there is any change in the acceleration request set forth above, the Company, or our outside counsel Thompson Coburn LLP, will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may be made by an executive officer of the Company or David Kaufman of Thompson Coburn LLP.
Once the Registration Statement is effective, we would appreciate confirmation to our counsel, Thompson Coburn LLP, by calling David Kaufman at (312) 580-2342.
If you have any questions regarding this request, please contact David Kaufman at (312) 580-2342.
Sincerely,
/s/ DAVID A. MARTIN
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Titan International, Inc.
1525 Kautz Road, Suite 600
West Chicago, IL 60185
December 20, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, NE
Washington, D.C. 20549
Attn: Evan Ewing and Jay Ingram
Re: Titan International, Inc.
Registration Statement on Form S-3
Filed November 1, 2024
File No. 333-282964
REQUEST FOR ACCELERATION OF EFFECTIVENESS
Dear Messrs. Ewing and Ingram:
Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Act”), Titan International, Inc., a Delaware corporation (the “Company,” “we,” “our” or “us”), hereby requests that the effectiveness of the above-referenced Registration Statement on Form S-3 (File No. 333-282964) (the “Registration Statement”) be accelerated to, and that the Registration Statement become effective at, 1 p.m. Eastern Time on December 20, 2024, or as soon thereafter as practicable. In making this acceleration request, the Company acknowledges that it is aware of its responsibilities under the Act.
If there is any change in the acceleration request set forth above, the Company, or our outside counsel Thompson Coburn LLP, will promptly notify you of the change, in which case the Company may be making an oral request of acceleration of the effectiveness of the Registration Statement in accordance with Rule 461. Such request may be made by an executive officer of the Company or David Kaufman of Thompson Coburn LLP.
Once the Registration Statement is effective, we would appreciate confirmation to our counsel, Thompson Coburn LLP, by calling David Kaufman at (312) 580-2342.
If you have any questions regarding this request, please contact David Kaufman at (312) 580-2342.
Sincerely,
/s/ DAVID A. MARTIN
David Martin
Chief Financial Officer
Titan International, Inc.
Cc: David J. Kaufman, Esq.