SecProbe.io

December 28 , 2012

Via U.S. 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 14, 2012
Form 10 -Q for Fiscal Quarter Ended
September 30, 2012
File No. 001 -01927

Dear Mr. Wells :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the request ed
response.   If you do not believe our comments apply to your facts and circumstances or do not
believe an amendment is appropriate, please  tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Note 4 – Sale of Farm Tire and Wire Business, page 73

1. You disclose that Titan is no longer obligated to purchase your European farm tire
business and due to the uncertainty surrounding  the timing of the completion of the
Amiens social plan, the European farm tire business was classified as held -and-used at
December 31, 2010 , and through the expiration of the put option on November 30, 2011.
Please tell us how you are accounting for the  European farm tire business as of December
31, 2011, and each fiscal quarter of 2012.  Please also quantify the assets and liabilities of
the tire business and whether you have assessed those assets for impairment.

Note 6 – Income Taxes, page 74

2. You di sclose that you had a tax benefit of $64 million related to the release of a valuation
allowance on your Canadian Operations.  We note that had you not released the valuation

Mr. Darren R. Wells
The Goodyear Tire & Rubber Company
December 2 8, 2012
Page 2

 your tax expense of  $201 million would have been 32 % higher and net income would
have decreased by 15%.  In future filings please provide a discussion of material changes
in your tax valuation and the underlying reasons.  Refer to Section 501.04 of the
Financial Reporting Codification for guidance.

Note 19 – Commitments and Contingent Liabilities, page 103

3. For your potential product liability and other tort claims, environmental matters, worker s’
compensation and other contingencies, please disclose the amount or range of reasonably
possible losses or a  statement that such amount can not be estimated.   If the reasonably
possible range of loss is immateria l to the financial stateme nts, please provide a s tatement
to that effect.  Refer to ASC 450 -20-50 and SAB Topic 5:Y for guidance.

Form 10 -Q for the Quarterly Period Ended September 30, 2012

Note   14. Consolidating Financial Information, page 26

4. We note that you have provided condensed consolidating financial information in
accordance with Rule 3 -10 of Regulation S -X for the 7% senior notes due 2022, the
8.25% senior  notes due 2020 and the 8.75% notes due 2020.   We note that the Indenture
for each of these notes contains certain subsidiary guarantor release provisions, including
a provision permitting the company to release a subsidiary guarantor during a
“Suspension Period.”   Please explain why you believe the guarantors are full and
unconditional as required by Rule 3 -10 of Regulation S -X in light of the provision that
allows for a release of the guarantor during a “Suspension Period.”

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the com pany may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Mr. Darren R. Wells
The Goodyear Tire & Rubber Company
December 2 8, 2012
Page 3

 You may contact Tracey McKoy at (202) 551 -3772 or me at (202) 551 -3355  if you have
question s regarding comments on the financial statements and related matters.  Please contact
Erin Jaskot at (202) 551 -3442 with any other questions.

Sincerely,

 /s/ Terence O’Brien

Terence O’Brien
Accounting Branch Chief