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 January 22, 2026

Robert Larsen
Chief Financial Officer
Titan Machinery Inc.
644 East Beaton Drive
West Fargo, ND 58078-2648

 Re: Titan Machinery Inc.
 Form 10-K for Fiscal Year Ended January 31, 2025
 File No. 1-33866
Dear Robert Larsen:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment(s).

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for Fiscal Year Ended January 31, 2025
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Critical Accounting Policies and Use of Estimates
Goodwill, page 39

1. Please provide information for investors to assess the probability of
future goodwill
 impairment charges. For example, please disclose whether your reporting
units are at risk
 of failing the quantitative impairment test or that the fair value is
substantially in excess
 of carrying value and is not at risk of failing. If a reporting unit is
at risk of failing, you
 should disclose:

 the percentage by which fair value exceeded carrying value at the
date of the most
 recent test;

 a more detailed description of the methods and key assumptions used
and how the key
 assumptions were determined;

 a discussion of the degree of uncertainty associated with the
assumptions; and
 January 22, 2026
Page 2

 a description of potential events and/or changes in circumstances
that could reasonably
 be expected to negatively affect the key assumptions.

 Please refer to Item 303(b)(3) of Regulation S-K.
 In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

 Please contact Ta Tanisha Meadows at 202-551-3322 or Adam Phippen at
202-551-3336
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Trade &
Services
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