SecProbe.io

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								August 1, 2006

Via Facsimile (330) 796-7861 and US Mail

Robert J. Keegan
Chief Executive Officer
Goodyear Tire & Rubber Company
1144 East Market Street
Akron, Ohio  44316

	Re:	Goodyear Tire & Rubber Company
		Form 10-K for the Fiscal Year Ended December 31, 2005
      Filed February 17, 2006
      Response Letter Dated July 17, 2006
 		File No. 1-1927

Dear Mr. Keegan:

      We have reviewed your response letter dated July 17, 2006
and
have the following comment.  After reviewing this information, we
may
raise additional comments.

General

1. We note your response to prior comments one and two.  Please
expand your description of contacts and your materiality analysis
to
describe and address:

* The nature of the products sold to customers in Iran, Syria and
Sudan in 2005;

* Whether or not the governments of these countries, or entities
controlled by them, purchased your products and, if applicable,
any
military uses made of your products by these governments;

* Information responsive to prior comments one and two for the
years
2003 and 2004, if you or your subsidiaries sold to customers in
Iran,
Syria or Sudan during those years;

* The principal reasons underlying your assessment that the sales
are
immaterial from a qualitative standpoint.  With respect to the
underlying reasons, we note your statement that none of the sales
were in violation of the laws of the U.S.  Please discuss the
possibility that, notwithstanding the legality of your foreign
subsidiaries` contacts with Iran, Sudan and Syria, your reputation
and share value may be negatively impacted by the fact that your
subsidiaries do business in these countries that have been
identified
as terrorist-sponsoring states.  In this regard, we call to your
attention the investor sentiment underlying the legislative and
other
initiatives described in our prior comment two.

Please also describe any other factors you considered in your
assessment.

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please understand
that
we may have additional comments after reviewing your response to
our
comment.  Please file your response letter on EDGAR.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comments or our review.  You may also contact
me
at (202) 551-3470.

								Sincerely,

								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Pam Long
		Assistant Director
		Division of Corporation Finance

Robert J. Keegan
Goodyear Tire & Rubber Company
August 1, 2006
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