United States securities and exchange commission logo
December 27, 2023
David A. Martin
SVP and Chief Financial Officer
Titan International, Inc.
1525 Kautz Road, Suite 600
West Chicago, IL 60185
Re: Titan
International, Inc.
Form 10-K for the
Year Ended December 31, 2022
File No. 001-12936
Dear David A. Martin:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the year ended December 31, 2022
Notes to the Consolidated Financial Statementsiness and Significant
Accounting Policies
1. Description of Business and Significant Accounting Policies
Revenue Recognition, page F-12
1. We note your revenue
recognition policy on page F-12; however, we do not consider the
information sufficient
in meeting the disclosure objective of the ASC 606-10-50.
The objective of the
disclosure requirements is for an entity to disclose sufficient
information to enable
users of financial statements to understand the nature, amount,
timing, and uncertainty
of revenue and cash flows arising from your contracts with
customers.
Consideration should be given to the level of detail necessary to satisfy the
disclosure objective.
In this regard, the information should be specific to the company and
avoid the use of
boilerplate language. Please revise accordingly.
2. We note from your
disclosures throughout the filing the company designs, manufactures
and sells products to
OEMs and aftermarket customers. In this regard, please tell us how
you considered the
guidance outlined in ASC 606-10-50-5 and paragraphs ASC 606-10-
David A. Martin
Titan International, Inc.
December 27, 2023
Page 2
55-89 to 91 in determining the categories to use for disaggregating
revenues that depict
how the nature, amount, timing, and uncertainty of revenue and cash
flows are affected by
economic factors such as, but not limited to, OEMs and aftermarket
customers.
28. Segment and Geographical Information, page F-32
3. Please revise your segment footnote to comply with the disclosures
requirements in ASC
280-10-50-29 and 40.
In closing, 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.
Please contact Jeff Gordon at 202-551-3866 or Jean Yu at 202-551-3305
with any
questions.
FirstName LastNameDavid A. Martin Sincerely,
Comapany NameTitan International, Inc.
Division of
Corporation Finance
December 27, 2023 Page 2 Office of
Manufacturing
FirstName LastName