SEC Comment Letter for Titan Machinery Inc. (TITN) (CIK 0001409171) (TITN) — Aug 23, 2007
Titan Machinery Inc. (TITN) (CIK 0001409171)
Date: Aug. 23, 2007 · CIK: 0001409171 · Accession: 0000000000-07-041358
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-145526
Letter
Mail Stop 3561 August 21, 2007 David J. Meyer Chairman and Chief Executive Officer Titan Machinery Inc. 4876 Rocking Horse Circle Fargo, ND 58104-6049
Re: Titan Machinery Inc. Registration Statement on Form S-1 Filed August 17, 2007 File No. 333-145526
Dear Mr. Meyer:
This is to advise you that a preliminar y review of the above registration statement indicates that it fails in numerou s material respects to comply with the requir ements of the Securities Act of 1933, th e rules and regulations under that Act, and th e requirements of the form. For this reason, we will not perfor m a detailed examination of the registration statement, and we will not issue any comments because to do so would delay the review of other disclosure documents th at do not appear to contai n comparable deficiencies.
You are advised that we will not recommend acceleration of the effective date of the registration statement and that, should the registration statem ent become effective in its present form, we would be re quired to consider what reco mmendation, if any, we should make to the Commission.
We suggest that you cons ider submitting a substantive amendment to correct the deficiencies or a request fo r withdrawal of the filing.
S i n c e r e l y ,
H . C h r i s t o p h e r O w i n g s A s s i s t a n t D i r e c t o r
cc via facsimile (612) 492-7077 Robert K. Ranum, Esq. Fredrikson & Byron, P.A.
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Mail Stop 3561
August 21, 2007
David J. Meyer
Chairman and Chief Executive Officer
Titan Machinery Inc.
4876 Rocking Horse Circle
Fargo, ND 58104-6049
Re: Titan Machinery Inc.
Registration Statement on Form S-1
Filed August 17, 2007
File No. 333-145526
Dear Mr. Meyer:
This is to advise you that a preliminar y review of the above registration statement
indicates that it fails in numerou s material respects to comply with the requir ements of the
Securities Act of 1933, th e rules and regulations under that Act, and th e requirements of the
form. For this reason, we will not perfor m a detailed examination of the registration
statement, and we will not issue any comments because to do so would delay the review of
other disclosure documents th at do not appear to contai n comparable deficiencies.
You are advised that we will not recommend acceleration of the effective date of the
registration statement and that, should the registration statem ent become effective in its
present form, we would be re quired to consider what reco mmendation, if any, we should
make to the Commission.
We suggest that you cons ider submitting a substantive amendment to correct the
deficiencies or a request fo r withdrawal of the filing.
S i n c e r e l y ,
H . C h r i s t o p h e r O w i n g s
A s s i s t a n t D i r e c t o r
cc via facsimile (612) 492-7077
Robert K. Ranum, Esq.
Fredrikson & Byron, P.A.