United States securities and exchange commission logo November 22, 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 Filed March 31, 2021 File No. 1-33866 Dear Mr. Kalvoda: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services