SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — May 4, 2009
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: May 4, 2009 · CIK: 0000042582 · Accession: 0000000000-09-023552
AI Filing Summary & Sentiment
Reasoning
Referenced dates: April 24, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010
DIVISION OF CORPORATION FINANCE
May 1, 2009
By U.S. mail and facsimile to (330) 796-7506
Mr. Darren R. Wells, Executive Vice President and Chief Financial Officer The Goodyear Tire & Rubber Company 1144 East Market Street Akron, OH 44316 RE: The Goodyear Tire & Rubber Company Form 10-K for the fiscal year ended December 31, 2008 Filed February 18, 2009 Form 10-Q for the peri od ended March 31, 2009 File No. 1-01927 Dear Mr. Wells:
We have reviewed your response letter dated April 24, 2009 and have the following additional comment. If you disagree , we will consider your explanation as to why our comment is inapplicable. We ma y ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Form 10-Q for the period ended March 31, 2009
Management’s Discussion and Analysis, page 25
1. We have read your response to prior comment 4 and the disclosure in your March 31, 2009, Form 10-Q. Please clarify how you considered the guidance in paragraph 28 of SFAS 142 in deciding not to perform an interim impairment test of goodwill for EMEA and Asia Pacific Tire as of December 31, 2008, and March 31, 2009. Please clarify how your analysis of the significance of the difference between fair value over ca rrying value as of July 31, 2008, resulted in your conclusion for both reporting units at December 31, 2008. As of March 31, 2009, clarify how you determined the significant adverse change in the business climate and changes in segment performance for EMEA and Asia Pacific Tire did not meet the criteria in paragraph 28.
Mr. Darren R. Wells The Goodyear Tire & Rubber Company May 1, 2009 Page 2 * * * *
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 that keys your responses to our comments and provides any requested supplemental information. Detailed response letters greatly facilitate our review. Please file your response letter on EDGAR. Please understand that we may have additional comments after reviewing your responses to our comments. You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3355 if you have questions regarding these comments.
S i n c e r e l y , T e r e n c e O ’ B r i e n B r a n c h C h i e f
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
May 1, 2009
By U.S. mail and facsimile to (330) 796-7506
Mr. Darren R. Wells, Executive Vice President and Chief Financial Officer The Goodyear Tire & Rubber Company 1144 East Market Street Akron, OH 44316
RE: The Goodyear Tire & Rubber Company
Form 10-K for the fiscal year ended December 31, 2008
Filed February 18, 2009
Form 10-Q for the peri od ended March 31, 2009
File No. 1-01927
Dear Mr. Wells:
We have reviewed your response letter dated April 24, 2009 and have the
following additional comment. If you disagree , we will consider your explanation as to
why our comment is inapplicable. We ma y ask you to provide us with supplemental
information so we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments. Form 10-Q for the period ended March 31, 2009
Management’s Discussion and Analysis, page 25
1. We have read your response to prior comment 4 and the disclosure in your March
31, 2009, Form 10-Q. Please clarify how you considered the guidance in
paragraph 28 of SFAS 142 in deciding not to perform an interim impairment test
of goodwill for EMEA and Asia Pacific Tire as of December 31, 2008, and March 31, 2009. Please clarify how your analysis of the significance of the difference
between fair value over ca rrying value as of July 31, 2008, resulted in your
conclusion for both reporting units at December 31, 2008. As of March 31, 2009,
clarify how you determined the significant adverse change in the business climate
and changes in segment performance for EMEA and Asia Pacific Tire did not
meet the criteria in paragraph 28.
Mr. Darren R. Wells
The Goodyear Tire & Rubber Company May 1, 2009 Page 2
* * * *
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 that keys your
responses to our comments and provides any requested supplemental information.
Detailed response letters greatly facilitate our review. Please file your response letter on
EDGAR. Please understand that we may have additional comments after reviewing your
responses to our comments.
You may contact Jenn Do at (202) 551-3743, or me at (202) 551-3355 if you have
questions regarding these comments.
S i n c e r e l y , T e r e n c e O ’ B r i e n B r a n c h C h i e f