SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Jan 16, 2014

GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Jan. 16, 2014 · CIK: 0000042582 · Accession: 0000000000-14-002574

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

February 12, 2013

Author

/s/ Melissa N. Rocha

Form

UPLOAD

Company

GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)

Letter

January 1 6, 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 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 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 la ws of the United States. 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 rules require.

Sincerely,
/s/ Melissa N. Rocha

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January 1 6, 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 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 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 la ws of the United States.  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 rules require.

Sincerely,

        /s/ Melissa N. Rocha

        Melissa N. Rocha
        Senior Assistant Chief Accountant

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