SEC Comment Letter for Titan Machinery Inc. (TITN) (CIK 0001409171) (TITN) — Jul 8, 2013
Titan Machinery Inc. (TITN) (CIK 0001409171)
Date: July 8, 2013 · CIK: 0001409171 · Accession: 0000000000-13-036929
AI Filing Summary & Sentiment
Reasoning
Letter
July 8, 2013 Via E-mail Mark P. Kalvoda Chief Financial Officer Titan Machinery Inc. 644 East Beaton Drive West Fargo, ND 58078
Re: Titan Machinery Inc. Form 8 -K Filed July 2 , 2013 File No. 1-33866
Dear Mr. Kalvoda :
We have reviewed your filing and have the following comment . In our comment , we may ask you to provide us with more information so we may better understand your disclosure.
Please respond to this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comment s.
Item 4.01 Changes in Registrant’s Certifying Accountant
1. Please revise your disclosure in the last paragraph to state, if true, that you did not consult with Deloitte during the two most recent years and any subsequent interim period prior to engagin g that accountant. Refer to paragraph (a)(2) of Item 304 of Regulation S -K.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Ex change Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comment , please provide a written statement from the company acknowledging that:
the company is responsible for the adequacy and accuracy of the disclosure in the filing;
Mark P. Kalvoda Titan Machinery Inc. July 8, 2013 Page 2
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of t he United States.
You may contact Yolanda Guobadia at (202) 551 -3562 if you have questions. In her absence you may contact me at (202) 551 -3344.
Sincerely,
/s/ William H. Thompson
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July 8, 2013 Via E-mail Mark P. Kalvoda Chief Financial Officer Titan Machinery Inc. 644 East Beaton Drive West Fargo, ND 58078 Re: Titan Machinery Inc. Form 8 -K Filed July 2 , 2013 File No. 1-33866 Dear Mr. Kalvoda : We have reviewed your filing and have the following comment . In our comment , we may ask you to provide us with more information so we may better understand your disclosure. Please respond to this letter within five business days by amending your filing, by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment , we may have additional comment s. Item 4.01 Changes in Registrant’s Certifying Accountant 1. Please revise your disclosure in the last paragraph to state, if true, that you did not consult with Deloitte during the two most recent years and any subsequent interim period prior to engagin g that accountant. Refer to paragraph (a)(2) of Item 304 of Regulation S -K. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes the information the Securities Ex change Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comment , please provide a written statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filing; Mark P. Kalvoda Titan Machinery Inc. July 8, 2013 Page 2 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of t he United States. You may contact Yolanda Guobadia at (202) 551 -3562 if you have questions. In her absence you may contact me at (202) 551 -3344. Sincerely, /s/ William H. Thompson William H. Thompson Accounting Branch Chief