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                              November 12, 2021

       Mark Kalvoda
       Chief Financial Officer
       Titan Machinery Inc.
       644 East Beaton Drive
       West Fargo, ND 58078-2648

                                                        Re: Titan Machinery
Inc.
                                                            Form 10-K for the
Fiscal Year Ended January 31, 2021
                                                            Response dated
November 5, 2021
                                                            File No. 1-33866

       Dear Mr. Kalvoda:

              We have reviewed your November 5, 2021 response to our comment
letter and have the
       following comments. In some of our comments, we may ask you to provide
us with information
       so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       October 25, 2021 letter.

       Form 10-K for the Fiscal Year Ended January 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Financial Measures, page 38

   1.                                                   We note your response
to comment 1. Removing the impact of your valuation allowance
                                                        appears to be an
individually tailored income tax recognition method. Please revise your
                                                        presentation to remove
this adjustment or tell us why you believe it is not an individually
                                                        tailored recognition
method. Refer to Question 100.04 of the Staff's Compliance and
                                                        Disclosure
Interpretations on Non-GAAP Financial Measures.
       Adjusted Cash Flow Reconciliation, page 42

   2.                                                   We note your response
to comment 2. Your response states that you consider cash flow
                                                        adjusted for a constant
percentage of equity in equipment inventory as a supplement to
 Mark Kalvoda
Titan Machinery Inc.
November 12, 2021
Page 2
         GAAP cash flow. Further, your presentation of adjusted cash flow is
reconciled to cash
         flow provided by operating activities which is a liquidity measure. In
light of these facts,
         please explain in further detail how Adjusted Cash Flow is not a
liquidity measure.
         Finally, please tell us your consideration of the guidance in Item
10(e)(1)(ii)(A) of
         Regulation S-K related to your adjustment for constant equity in
equipment inventory.
       You may contact Tony Watson at (202) 551-3318 or Adam Phippen at (202)
551-3336 if
you have questions regarding comments on the financial statements and related
matters.



FirstName LastNameMark Kalvoda                                 Sincerely,
Comapany NameTitan Machinery Inc.
                                                               Division of
Corporation Finance
November 12, 2021 Page 2                                       Office of Trade
& Services
FirstName LastName