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                                                            November 19, 2024

Bill Zarkalis
Chief Executive Officer
Titan America SA
1000 Bruxelles
Square de Mee  s 37, Belgium

        Re: Titan America SA
            Amendment No. 1 to Draft Registration Statement on Form F-1
            Submitted November 4, 2024
            CIK No. 0002035304
Dear Bill Zarkalis:

     We have reviewed your amended draft registration statement and have the
following
comments.

       Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our October 11, 2024 letter.

Amendment No. 1 to Draft Registration Statement on Form F-1
Financial Metrics and Financial Highlights, page 75

1.     We note you present Ratio of Net Debt to Adjusted EBITDA, a non-IFRS
financial
       measure, in the Financial Metrics and Financial Highlights table. Please
revise your
       disclosure to present, with equal or greater prominence, the most
directly comparable
       IFRS financial measure, Ratio of Total Debt to Net income. Refer to Item
       10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Compliance
       & Disclosure Interpretations regarding Non-GAAP Financial Measures.
 November 19, 2024
Page 2
Financial Metrics and Financial Highlights, page 76

2.     We note you present and discuss year-over-year changes in Free Cash Flow
and Ratio
       of Net Debt to Adjusted EBITDA, non-IFRS financial measures, on page 76.
Please
       revise your disclosure to present, with equal or greater prominence, the
year-over-year
       changes in the most directly comparable IFRS financial measures. Refer
to Item
       10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of the Compliance
       & Disclosure Interpretations regarding Non-GAAP Financial Measures.
Liquidity and Capital Resources, page 94

3.     We note your response to prior comment 8. Please tell us why you do not
believe that
       agreements relating to your lease liabilities are material pursuant to
Item 601(b)(10).
Exhibit 96.1, page II-2

4.     We note your response to prior comments 28 and 29. We are able to
calculate your net
       revenue numbers in Tale 19-1 based on the pricing data from Section
19.1.1 and the
       production parameters in Section 19.1.4, however we are unable to
reconcile the
       operating expenses in Table 19-1 with the mining and processing costs
and/or unit
       mining costs from Section 18. Please provide addition disclosure in this
regard.

       Please include process capital costs in section 18.

       Additionally please provide a total column in Table 19-1.
Exhibit 96.2, page II-2

5.     We note your response to prior comments 33 and 34. We are able to
calculate your net
       revenue numbers in Tale 19-1 based on the pricing data from Section
19.1.1 and the
       production parameters in Section 19.1.5, however we are unable to
reconcile the
       operating expenses in Table 19-1 with the mining and processing costs
and/or unit
       mining costs from Section 18. Please provide addition disclosure in this
regard.

       Please include process capital costs in section 18.

       Additionally please provide a total column in Table 19-1.
 November 19, 2024
Page 3

        Please contact Ranjit Singh Pawar at 202-551-2702 or Kimberly Calder at
202-551-
3701 if you have questions regarding comments on the financial statements and
related
matters. You may contact John Coleman at 202-551-3610 for questions regarding
the
engineering comments. Please contact Claudia Rios at 202-551-8770 or Liz
Packebusch at
202-551-8749 with any other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Energy &
Transportation
cc:   Jeffrey D. Karpf, Esq.
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