Craig-Hallum Capital Group LLC
222 South Ninth Street, Suite 350
Minneapolis, Minnesota 55402
December 5, 2007
Securities and Exchange Commission | BY EDGAR AND FACSIMILE |
100 F Street, N.E., Mail Stop 3561 |
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Washington, DC 20549 |
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Re: | Titan Machinery Inc. |
| Registration Statement on Form S-1 (File No. 333-145526) |
Ladies and Gentlemen:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, the undersigned hereby join Titan Machinery Inc. in requesting that the effective date of the above referenced Registration Statement on Form S-1 be accelerated and that such Registration Statement be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time on Wednesday, December 5, 2007, or as soon thereafter as possible.
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended, please be advised that between November 16, 2007 and November 30, 2007, as of 12:00 noon Eastern Time, the undersigned have effected approximately the following distribution of copies of the Preliminary Prospectus, dated November 16, 2007:
FINRA |
| 0 |
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Underwriters |
| 1,658 |
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Dealers |
| 0 |
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Institutions |
| 1,056 |
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Others |
| 0 |
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Total |
| 2,714 Copies |
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| Very truly yours, | ||
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| CRAIG-HALLUM CAPITAL GROUP LLC | ||
| ROBERT W. BAIRD & CO. INCORPORATED | ||
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| BY: | CRAIG-HALLUM CAPITAL GROUP LLC | |
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| As Representative of the Underwriters | |
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| /s/ | John L. Flood |
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| John L. Flood |
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| Managing Partner | ||
