SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Jan 28, 2013
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Jan. 28, 2013 · CIK: 0000042582 · Accession: 0000000000-13-004687
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January 25, 2013
Via E -mail
Mr. Richard J. Kramer
Chief Executive Officer
The Goodyear Tire & Rubber Company
1144 East Market Street
Akron, Ohio 44316 -0001
RE: The Goodyear Tire & Rubber Company
Form 10-K for the Fis cal Year Ended December 31 , 201 1
Filed February 14 , 2012
File No . 1-1927
Dear Mr. Kramer :
We have completed our review of your filing. We remind you that our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
federal securit ies laws of the United States. We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s includes the
information the Securities Exchange Act of 1934 and all applicable rules requ ire.
Sincerely,
/s/ John Cash, for
Terence O’Brien
Accounting Branch Chief