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CORRESP Filing
Titan International (TWI) CORRESPCorrespondence with SEC
Filed: 11 Jul 18, 12:00am
Titan International, Inc.
2701 Spruce Street
Quincy, IL 62301
VIA EDGAR
July 11, 2018
Sherry Haywood
United States Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549
Re: Titan International, Inc.
Registration Statement on FormS-4
FileNo. 333-225442
Dear Ms. Haywood:
Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, in connection with the above-referenced registration statement (the “Registration Statement”) filed by Titan International, Inc., a Delaware corporation (the “Company”) and the Company’s 100% owned subsidiaries named in the Registration Statement (together with the Company, the“Co-Registrants”), theCo-Registrants hereby request that effectiveness under the Securities Act of 1933, as amended, of the Registration Statement be accelerated to 11:00 a.m. Eastern Daylight Time, July 17, 2018, or as soon thereafter as practicable.
Please do not hesitate to contact me at (217)221-4389 ormike.troyanovich@titan-intl.com with any questions you may have concerning this request. In addition, please notify me when this request for acceleration has been granted.
Very truly yours,
Titan International, Inc.
Titan Wheel Corporation of Illinois
Titan Tire Corporation
Titan Tire Corporation of Bryan
Titan Tire Corporation of Freeport
/s/ Michael G. Troyanovich
Michael G. Troyanovich
General Counsel