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SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — May 15, 2013

GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: May 15, 2013 · CIK: 0000042582 · Accession: 0000000000-13-026730

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Document Type
Confidence
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Summary

Reasoning

Referenced dates: April 16, 2013

Date
May 15, 2013
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)

Letter

UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 DIVISION OF CORPORATION FINANCE May 15, 2013 Via E -mail Richard J. Kramer Chairman of the Board, Chief Executive Officer, and President The Goodyear Tire & Rubber Company 1144 East Market Street Akron, Ohio 44316 -0001

Re: The Goodyear Tire & Rubber Company Form 10 -K for the Fiscal Year Ended December 31, 2012 Filed February 12, 2013 File No. 1 -01927

Dear Mr. Kramer:

We refer you to our comment letter dated April 16, 2013, regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. 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 and the company 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. We urge all persons who are responsible for the accuracy and adequac y of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,
/s/ Cecilia Blye

Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
                  WASHINGTON, D.C. 20549

      DIVISION OF
CORPORATION FINANCE

May 15, 2013

Via E -mail
Richard J. Kramer
Chairman of the Board, Chief Executive Officer, and President
The Goodyear Tire & Rubber Company
1144 East Market Street
Akron, Ohio 44316 -0001

 Re: The Goodyear Tire & Rubber Company
  Form 10 -K for the Fiscal Year Ended December 31, 2012
  Filed February 12, 2013
  File No. 1 -01927

Dear Mr. Kramer:

We refer you to our comment letter dated April 16, 2013, regarding business contacts
with Sudan and Syria.  We have completed our review of this subject matter.  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 and the company
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.  We urge all persons who are
responsible for the accuracy and adequac y of the disclosure in the filing to be certain that the
filing includes the information the Securities Exchange Act of 1934 and all applicable rules
require.

         Sincerely,

         /s/ Cecilia Blye

         Cecilia Blye, Chief
         Office of Global Security Risk

cc:  Pamela Long
  Assistant Director
 Division of Corporation Finance