Mail Stop 7010

      January 5, 2006

via U.S. mail and facsimile

Mr. Maurice M. Taylor Jr.
President and Chief Executive Officer, Titan International, Inc.
2701 Spruce Street
Quincy, IL  62301

	RE:	Form 10-K for the fiscal year ended December 31, 2004
			File No. 1-12936

Dear Mr. Taylor:


      We have completed our review of your Form 10-K and related
filings and have no further comments at this time.

      If you have any further questions regarding our review of
your
filings, please direct them to Marie Trimeloni, Staff Accountant,
at
(202) 551-3734 or, in her absence, to the undersigned at (202)
551-
3769.

							Sincerely,


							Rufus Decker
							Accounting Branch Chief
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Mr. J. Gordon Beittenmiller
March 25, 2005
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE