August 16, 2019

John Sheehan
Chief Financial Officer
Terex Corporation
200 Nyala Farm Road
Westport, CT 06880

       Re: Terex Corporation
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 25, 2019
           Form 10-Q for the Quarterly Period Ended June 30, 2019
           Filed July 30, 2019
           File No. 001-10702

Dear Mr. Sheehan:

       We have reviewed your filings 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.

Form 10-K for the Fiscal Year Ended December 31, 2018

Notes To Consolidated Financial Statements
Note B   Business Segment Information, page F-17

1.    Please revise future filings to present separately revenues from external
customers
      attributed to your country of domicile. Also, when material, separately
disclose the
      revenues from external customers attributed to an individual foreign
country. Refer to
      ASC 280-10-50-41(a).
 John Sheehan
Terex Corporation
August 16, 2019
Page 2
Form 10-Q for the Six Months Ended June 30, 2019

Note B   Business Segment Information, page 11

2.       We note on page 8 and throughout the filing that you sold a portion of
your Cranes
         segment and that you are now reporting your business in two segments.
We further note
         that your utilities business has been consolidated within your AWP
segment, your pick
         and carry cranes business has been consolidated within your MP
segment, and your rough
         terrain and tower cranes businesses have been consolidated within
Corporate and Other.
         So that we may better understand your assessment of your operating
segments and how
         you comply with ASC 280, please explain to us why you believe that
each of these
         businesses have economic characteristics similar to the other
operating segments within
         the AWP and MP reportable segments and how they meet the requirements
to be
         aggregated in accordance with ASC 280-10-50-11.
        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.

       You may contact Tara Harkins at (202)-551-3639 or Lynn Dicker, Senior
Accountant, at
(202)-551-3616 with any questions.



FirstName LastNameJohn Sheehan                              Sincerely,
Comapany NameTerex Corporation
                                                            Division of
Corporation Finance
August 16, 2019 Page 2                                      Office of
Electronics and Machinery
FirstName LastName