SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

                May 21, 2010

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, 2009
Filed February 19, 2010
  File No. 1-1927

Dear Mr. Wells:
We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your disclosures in future filings in response to these comments.  If you disagree, we will consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary in your explanation.  In some of our comme nts, we may 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-K for the year ended December 31, 2009

 Management’s Discussion and Analysis, page 28

 Liquidity and Capital Resources, page 45

1. In your response to comment 4, you discuss how you have disclosed specific items relating to your Venezuelan subsidia ry when they are material to a broader
discussion of your Latin American Tire se gment or to overall liquidity.  Please
expand MD&A in future filings to provi de a more comprehensive discussion of
your Venezuelan operations that provides a greater level of information about the
monetary assets and liabilities that are e xposed to exchange rate changes and the
sensitivity of your sales and cost of sales to  future currency changes.  Disclose the
specific amount of bolivar-denominated mone tary assets and liabilities as of each
balance sheet date and provi de a break-out of the amounts being remeasured at
each exchange rate.  Provide this disclosu re at a reasonably detailed level; for
example, disclose amounts for cash and acc ounts receivable.  Disclose the amount
of sales and costs of sales for Goodyear Venezuela and separately disclose the

Mr. Darren R. Wells
The Goodyear Tire & Rubber Company
May 21, 2010 Page 2
amounts denominated in bolivar fuerte and the U.S. dollar.  Please provide us an
example of future disclosure.

2. In a response to us, you state you have not used the parallel mark et to settle U.S.
dollar-denominated accounts payable, intercompany amounts or other balances.  In future filings please provide a disc ussion of amounts you have settled at the
official rate during the pe riods presented or, if no amounts have been settled
during this time, discuss the most recent  settlements.  Disclose the amount of
bolivar fuerte pending government approval fo r settlement at the official rate (and
which official rate) and the length of tim e the request(s) have been pending.
Discuss the implications of the current exchange rate system for your operations and cash flows.  Please provide us an example of future disclosure.

3.   In future filings, please discuss your plans to manage the challenges presented by
the current exchange rate system.  For example, disclose changes in business
practices or policies that ha ve occurred or are anticipate d to occur in response to
the devaluation and the hyperi nflationary environment.

4. In a separate letter dated April 30, 2010, you provided us with summarized
financial information for Goodyear Venezu ela. Since it does not appear you have
requested confidential treatment pursuant to Rule 83 for the information, please
upload this information to EDGAR as correspondence.

Note 3. Other Expense, page 75

5.   We have read your response to co mment 5 in our letter dated April 23, 2010.
Please provide the clarifying language contai ned in your response in future filings
as applicable.

Mr. Darren R. Wells
The Goodyear Tire & Rubber Company May 21, 2010 Page 3
*    *    *    *
 Please respond to these comments 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 supplem ental information.  Detailed response
letters greatly facilitate our review.  Pleas e 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, St aff Accountant, at (202) 551-3743, or me at (202)
551-3355 if you have questions regarding comm ents on the financial statements and
related matters.

         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