SEC Company Response from Titan Machinery Inc. (TITN) (CIK 0001409171) (TITN) — Jan 19, 2011
Titan Machinery Inc. (TITN) (CIK 0001409171)
Date: Jan. 19, 2011 · CIK: 0001409171 · Accession: 0001104659-11-002047
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File numbers found in text: 333-171063
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CORRESP 1 filename1.htm January 19, 2011 VIA EDGAR AND FACSIMILE U.S. Securities and Exchange Commission Attn: H. Christopher Owings, Assistant Director 100 F Street NE Washington, DC 20549 Re: Titan Machinery Inc. Registration Statement on Form S-3 Filed December 9, 2010 File No. 333-171063 Dear Mr. Owings: Pursuant to Rule 461 under the Securities Act of 1933, as amended, Titan Machinery Inc. (the “Company”) requests acceleration of the effective date of the above-referenced Registration Statement so that the same shall become effective as of 4:00 p.m. Eastern Standard Time on January 21, 2011, or as soon thereafter as possible. The Company hereby acknowledges that: · Should the Commission or the 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 the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and · The Company 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. Sincerely, /s/ David J. Meyer David J. Meyer Chief Executive Officer