SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

       DIVISION OF
CORPORATION FINANCE

Mail Stop 7010
    November 26, 2008

By U.S. Mail and facsimile to (330) 796-7861

C. Thomas Harvie Senior Vice President, Gene ral Counsel and Secretary
The Goodyear Tire & Rubber Company 1144 East Market Street Akron, Ohio 44316-0001
Re: The Goodyear Tire & Rubber Company
 Form 10-K for Fiscal Year Ended
December 31, 2007
 Proxy Statement on Schedule 14A  Filed on March 7, 2008   File No. 1-01927

Dear Mr. Harvie:
 We have reviewed your response letter  dated November 10, 2008 and have the
following additional comments.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  Af ter reviewing this
information, we may raise additional comments.  We welcome any questions you may have about our comments or on any other aspect of our review.
1. We note your responses to prior comments 2 and 3 of our September 29, 2008
letter. However, the causal connectio n between the disclosure of your
performance targets and any competitive harm is not clear.  Please describe with greater specificity how the disclosure of performance targets would allow your
competitors to reach reasonable estimates regarding the underlying components of your financial performance targets in futu re periods and harm you competitively.
Refer to Instruction 4 of Item 402(b) of  Regulation S-K.  Please refer to prior
comments 2 and 3 for additional guidance, as appropriate.

Robert J. Keegan
The Goodyear Tire & Rubber Company November 26, 2008 Page 2

2. We note your statement that the perfor mance targets are not material in
determining the target awards granted to a named executive officer.  However,
please reconcile this with the disclosu re in the compensation discussion and
analysis on page 19 which indicates that your long term compensation in the form of performance shares and cash awards are tied to the achievement of specific financial objectives during a th ree year performance period.
3. You state that the number of target E PP units and performance shares granted
annually to each named executive officer is  based on a number of considerations.
Supplementally, explain how each of these subjective factors is weighted in the
Committee’s determination of the amount of target awards granted to each of the
named executive officers.

*  *  *  *  *  *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter on EDGAR that keys
your responses to our comments and provides any requested supplemental information.
Detailed response letters great ly facilitate our review.  Please understand that we may
have additional comments after review ing your responses to our comments.

Please direct questions to  Sherry Haywood, Staff Atto rney at (202) 551-3345, or
me at (202) 551-3760.

Sincerely,

Pamela Long Assistant Director

cc:  D.T. Young, Esq. ( via facsimile 330/ 796-8836)
      Law Department
      The Goodyear Tire & Rubber Company