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SEC Company Response from TITAN INTERNATIONAL INC (TWI) (CIK 0000899751) (TWI) — Jul 11, 2018

TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)
Date: July 11, 2018 · CIK: 0000899751 · Accession: 0001193125-18-216162

AI Filing Summary & Sentiment

File numbers found in text: 333-225442

Date
July 11, 2018
Author
Not clearly detected
Form
CORRESP
Company
TITAN INTERNATIONAL INC (TWI) (CIK 0000899751)

Letter

VIA EDGAR United States Securities and Exchange Commission Division of Corporation Finance Washington, D.C. Re: Titan International, Inc. Registration Statement on Form S-4 File No. 333-225442

Dear Ms. Haywood:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, in connection with the above-referenced registration statement (the “Registration Statement”) filed by Titan International, Inc., a Delaware corporation (the “Company”) and the Company’s 100% owned subsidiaries named in the Registration Statement (together with the Company, the “Co-Registrants”), the Co-Registrants hereby request that effectiveness under the Securities Act of 1933, as amended, of the Registration Statement be accelerated to 11:00 a.m. Eastern Daylight Time, July 17, 2018, or as soon thereafter as practicable.

Please do not hesitate to contact me at (217) 221-4389 or mike.troyanovich@titan-intl.com with any questions you may have concerning this request. In addition, please notify me when this request for acceleration has been granted.

Very truly yours,
Titan International, Inc.

Show Raw Text
CORRESP
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CORRESP

 Titan International, Inc.

2701 Spruce Street

Quincy, IL 62301

 VIA EDGAR

July 11, 2018

 Sherry Haywood

United States Securities and Exchange Commission

 Division of
Corporation Finance

 100 F. Street, N.E.

 Washington, D.C.
20549

 Re: Titan International, Inc.

Registration Statement on Form S-4

File No. 333-225442

Dear Ms. Haywood:

 Pursuant to Rule 461
promulgated under the Securities Act of 1933, as amended, in connection with the above-referenced registration statement (the “Registration Statement”) filed by Titan International, Inc., a Delaware corporation (the “Company”)
and the Company’s 100% owned subsidiaries named in the Registration Statement (together with the Company, the “Co-Registrants”), the Co-Registrants hereby
request that effectiveness under the Securities Act of 1933, as amended, of the Registration Statement be accelerated to 11:00 a.m. Eastern Daylight Time, July 17, 2018, or as soon thereafter as practicable.

Please do not hesitate to contact me at (217) 221-4389 or mike.troyanovich@titan-intl.com with
any questions you may have concerning this request. In addition, please notify me when this request for acceleration has been granted.

Very truly yours,

Titan International, Inc.

Titan Wheel Corporation of Illinois

Titan Tire Corporation

Titan Tire Corporation of Bryan

Titan Tire Corporation of Freeport

/s/ Michael G. Troyanovich

Michael G. Troyanovich

General Counsel