SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Dec 21, 2011
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Dec. 21, 2011 · CIK: 0000042582 · Accession: 0000000000-11-073059
AI Filing Summary & Sentiment
Reasoning
Referenced dates: December 1, 2011
Letter
December 21, 2011 Via E-mail 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 Filed February 10, 2011 File No. 1-1927
Dear Mr. Wells: We have reviewed your response and have the following comment. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the year ended December 31, 2010
19. Commitments and Contingent Liabilities, page 112
1. We have read your response to comment 1 in our letter dated December 1, 2011. You have told us that you have concluded th at the amounts related to your warranty experience as of and for the years ende d December 31, 2010 and 2009 were not material to your consolidated financial statements and therefore you did not include the full disclosure referred to in AS C 460-10-50-8c. We note that your warranty expense for 2010 has a 163% impact to your pre-tax inco me. Please either provide to us your materiality assessment or disclose in future filings the amount of the warranty expense and payments for the year so that reader s may understand the gro ss activity related to your warranties.
Mr. Darren R. Wells The Goodyear Tire & Rubber Company December 21, 2011 Page 2
You may contact Jenn Do at (202) 551-3743, Al Pavot at (2 02) 551-3738, or me at (202) 551-3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O’Brien Terence O’Brien Branch Chief
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December 21, 2011 Via E-mail 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 Filed February 10, 2011 File No. 1-1927 Dear Mr. Wells: We have reviewed your response and have the following comment. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comment applies to your facts a nd circumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10-K for the year ended December 31, 2010 19. Commitments and Contingent Liabilities, page 112 1. We have read your response to comment 1 in our letter dated December 1, 2011. You have told us that you have concluded th at the amounts related to your warranty experience as of and for the years ende d December 31, 2010 and 2009 were not material to your consolidated financial statements and therefore you did not include the full disclosure referred to in AS C 460-10-50-8c. We note that your warranty expense for 2010 has a 163% impact to your pre-tax inco me. Please either provide to us your materiality assessment or disclose in future filings the amount of the warranty expense and payments for the year so that reader s may understand the gro ss activity related to your warranties. Mr. Darren R. Wells The Goodyear Tire & Rubber Company December 21, 2011 Page 2 You may contact Jenn Do at (202) 551-3743, Al Pavot at (2 02) 551-3738, or me at (202) 551-3355 if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O’Brien Terence O’Brien Branch Chief