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SEC Company Response from TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Feb 16, 2007

TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: Feb. 16, 2007 · CIK: 0000899751 · Accession: 0000950124-07-000925

AI Filing Summary & Sentiment

File numbers found in text: 333-140121

Date
February 16, 2007
Author
Not clearly detected
Form
CORRESP
Company
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)

Letter

Re:

Titan International, Inc.

2701 Spruce Street

Quincy, IL 62301

February 16, 2007

Securities and Exchange Commission

Washington, D.C. 20549-0404

Titan International, Inc.

Registration Statement on Form S-4

File No.: 333-140121

Ladies and Gentlemen:

The purpose of this letter is to request on behalf of Titan International, Inc. (the “Registrant”) acceleration of the effectiveness of the above registration statement to February 21, 2007, pursuant to Rule 461(a).

The Registrant hereby acknowledges that:

•

should the Securities and Exchange Commission or its staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Registrant may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
TITAN INTERNATIONAL, INC.

Show Raw Text
CORRESP
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corresp

Titan International, Inc.

2701 Spruce Street

Quincy, IL 62301

February 16, 2007

Securities and Exchange Commission

Washington, D.C. 20549-0404

                   Re:

    Titan International, Inc.

Registration Statement on Form S-4

File No.: 333-140121

Ladies and Gentlemen:

          The purpose of this letter is to request on behalf of Titan International, Inc. (the
“Registrant”) acceleration of the effectiveness of the above registration statement to February 21,
2007, pursuant to Rule 461(a).

          The Registrant hereby acknowledges that:

    •

    should the Securities and Exchange Commission or its staff, acting pursuant to
delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;

    •

    the action of the Commission or its staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Registrant
from its full responsibility for the adequacy and accuracy of the disclosure in
the filing; and

    •

    the Registrant may not assert staff comments and the declaration of
effectiveness as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very truly yours,

TITAN INTERNATIONAL, INC.

    By:
    /s/ Maurice M. Taylor, Jr.

    Maurice M. Taylor, Jr.

    President and Chief Executive Officer