SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Jan 15, 2014
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Jan. 15, 2014 · CIK: 0000042582 · Accession: 0000000000-14-002109
AI Filing Summary & Sentiment
Reasoning
Letter
January 1 5, 2014 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 comment . If you disagree, we will consider your ex planation as to why our comment is 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing the information you provi de in response to this comment , 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 proposed revised disclosure to our prior comment that includes an allocation of pension costs between cost of goods sold and s elling, administrative and general expense on a consolidated basis. In future filings, please ensure your results of operations section of MD&A discusses the impact of your pensions on the above line items on a consolidated basis as well as operating inco me on a segment basis, including discussion of the factors contributing to any material year over year changes in pension costs.
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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January 1 5, 2014
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 comment . If
you disagree, we will consider your ex planation as to why our comment is 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 comment
applies to your facts and circumstances, please tell us why in your response. After reviewing the
information you provi de in response to this comment , 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 proposed revised disclosure to our prior comment that includes an
allocation of pension costs between cost of goods sold and s elling, administrative and general
expense on a consolidated basis. In future filings, please ensure your results of operations
section of MD&A discusses the impact of your pensions on the above line items on a
consolidated basis as well as operating inco me on a segment basis, including discussion of the
factors contributing to any material year over year changes in pension costs.
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