November 12, 2024

David Martin
Chief Financial Officer
TITAN INTERNATIONAL INC
1525 Kautz Road, Suite 600
West Chicago, IL 60185

       Re: TITAN INTERNATIONAL INC
           Registration Statement on Form S-3
           Filed November 1, 2024
           File No. 333-282964
Dear David Martin:

       We have conducted a limited review of your registration statement and
have the
following comment(s).

        Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Registration Statement on Form S-3
General

1.     Because Rule 415(a)(1)(i) of the Securities Act excludes from the
concept of
       secondary offerings sales by parents or subsidiaries of the issuer, it
appears that you
       may not register this transaction as a resale. Accordingly, please
revise the
       registration statement to set a fixed price for the duration of the
offering with the
       selling stockholder being designated as a statutory underwriter. Refer
to Securities
       Act Forms Question 116.15 of the Division of Corporation Finance   s
Compliance and
       Disclosure Interpretations.
        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.
 November 12, 2024
Page 2

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Evan Ewing at 202-551-5920 or Jay Ingram at 202-551-3397
with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Manufacturing