SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Dec 18, 2013
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Dec. 18, 2013 · CIK: 0000042582 · Accession: 0000000000-13-068801
AI Filing Summary & Sentiment
Reasoning
Letter
December 18, 2013 Via E -mail Ms. Laura K. Thompson Chief Financial Officer The Goodyear Tire & Rubber Company 200 Innovation Way Akron, OH 44316
RE: The Goodyear Tire & Rubber Company Form 10 -K for Fiscal Year Ended December 31, 201 2 Filed February 12, 2013 File No. 1 -01927
Dear M s. Thompson :
We have reviewed your response letter and have the following additional comments. If you disagree, we will consider your explanation as to why our comments are inapplicable. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If yo u do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewing the information you provide in response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2012
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 27
We note your response to prior comment 1. Given that a portion of pension costs is allocated to cost of goods sold, quantify how much of yo ur pension costs are capitalized as part of inventory at each balance sheet date. We note your proposed revised disclosure included in your response. Please revise your draft disclosure to include historical information so we may assess the effect of pen sion costs on cost of goods sold (CGS), selling, administrative and general expense (SAG) and operating income.
You may contact Thomas D’Orazio at (202) 551 -3825 or the undersigned Senior Assistant Chief Accountant at (202) 551 -3854 if you have any questions .
Sincerely,
/s/ Melissa N. Rocha
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December 18, 2013
Via E -mail
Ms. Laura K. Thompson
Chief Financial Officer
The Goodyear Tire & Rubber Company
200 Innovation Way
Akron, OH 44316
RE: The Goodyear Tire & Rubber Company
Form 10 -K for Fiscal Year Ended December 31, 201 2
Filed February 12, 2013
File No. 1 -01927
Dear M s. Thompson :
We have reviewed your response letter and have the following additional comments. If
you disagree, we will consider your explanation as to why our comments are inapplicable. Please
respond to this letter within ten business days by providing the requested information or by
advising us when you will provide the requested response. If yo u do not believe our comments
apply to your facts and circumstances, please tell us why in your response. After reviewing the
information you provide in response to these comments, we may have additional comments.
Form 10 -K for Fiscal Year Ended December 31, 2012
Management’s Discussion and Analysis of Financial Condition and Results of Operations,
page 27
We note your response to prior comment 1. Given that a portion of pension costs is
allocated to cost of goods sold, quantify how much of yo ur pension costs are capitalized as part
of inventory at each balance sheet date. We note your proposed revised disclosure included in
your response. Please revise your draft disclosure to include historical information so we may
assess the effect of pen sion costs on cost of goods sold (CGS), selling, administrative and
general expense (SAG) and operating income.
You may contact Thomas D’Orazio at (202) 551 -3825 or the undersigned Senior
Assistant Chief Accountant at (202) 551 -3854 if you have any questions .
Sincerely,
/s/ Melissa N. Rocha
Melissa N. Rocha
Senior Assistant Chief Accountant