1290 AVENUE OF THE AMERICAS
                            NEW YORK, NEW YORK 10104
                                 (212) 541-2000

                           FACSIMILE: (212) 541-4630

                               December 10, 2001

Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

    Re:    Terex Corporation
           File No. 333-74840
           Accession Number: 0000910643-01-500232
           Filing Date: December 10, 2001

Ladies and Gentlemen:

     Reference is hereby made to the Registration Statement on Form S-3 referred
to above filed by the Registrant with the Securities and Exchange Commission on
December 10, 2001. On behalf of the Registrant, the Registrant hereby amends the
facing page of such Registration Statement to include the following provision:

     The Registrant hereby amends this Registration Statement on such date or
     dates as may be necessary to delay its effective date until the Registrant
     shall file a further amendment which specifically states that this
     Registration Statement shall thereafter become effective in accordance with
     Section 8(a) of the Securities Act of 1933, or until the Registration
     Statement shall become effective on such date as the Commission, acting
     pursuant to said Section 8(a), may determine.

     If you have any questions or comments please feel free to contact Stuart
Gordon at Robinson Silverman Pearce Aronsohn & Berman LLP (212-541-2060).

                                         Very truly yours,

                                         /s/ Stuart A. Gordon
                                         Stuart A. Gordon