SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Nov 25, 2014
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Nov. 25, 2014 · CIK: 0000042582 · Accession: 0000000000-14-060477
AI Filing Summary & Sentiment
Reasoning
Referenced dates: November 21, 2014, November 7, 2014
Letter
November 25 , 2014 Via E -mail Laura K. Thompson Chief Financial Officer The Goodyear Tire & Rubber Company 200 Innovation Way Akron, Ohio 44316
Re: Goodyear Tire & Rubber Co Form 10 -K for Fiscal Year Ended December 31, 2013 Filed February 13, 2014 Form 10 -Q for Fiscal Quarter Ended September 30, 2014 Filed October 29, 2014 Response dated November 21, 2014 File No. 1-01927
Dear Ms. Thompson :
We have reviewed your response letter dated November 21, 2014, and have the following additional comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter w ithin ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response.
After reviewin g the information you provide in response to these comments, we may have additional comments.
Form 10 -Q for Fiscal Quarter Ended September 30, 2014 Note 11. Commitments and Contingent Liabilities, page 19
1. We note your response to comment 2 i n our letter dated November 7, 2014. While we appreciate that you began including the nature of the Greek Labor Cases in your footnote disclosures, there is a concern regarding compliance with ASC 450 -20-50-3 and ASC 450 - 20-50-4. Please expand your concl usion that you do not expect the outcome of this matter to material ly impact your results of operations to your financial position and cash flows. If it is reasonably possible that the amount of loss in excess of accrual could materially impact your results of operations, financial position, and/or cash flows; please disclose the range of reasonably possible loss in excess of accrual or disclose that you are unable to make such an estimate. Please provide us with the footnote disclosure you intend to includ e in your fiscal year 2014 Form 10 -K in response to this comment.
Ms. Thompson Goodyear Tire & Rubber Co November 25 , 2014 Page 2
You may contact Tracey Houser , Staff Accountant, at (202) 551 -3736, or in her absence, Melissa N. Rocha, Senior Assistant Chief Accountant , at (202) 551 -3854 , or me at (202) 551 - 3355, if you have questions regarding comments on the financial statements and related matters.
Sincerely,
/s/ Terence O ’Brien
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November 25 , 2014 Via E -mail Laura K. Thompson Chief Financial Officer The Goodyear Tire & Rubber Company 200 Innovation Way Akron, Ohio 44316 Re: Goodyear Tire & Rubber Co Form 10 -K for Fiscal Year Ended December 31, 2013 Filed February 13, 2014 Form 10 -Q for Fiscal Quarter Ended September 30, 2014 Filed October 29, 2014 Response dated November 21, 2014 File No. 1-01927 Dear Ms. Thompson : We have reviewed your response letter dated November 21, 2014, and have the following additional comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter w ithin ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circumstances, please tell us why in your response. After reviewin g the information you provide in response to these comments, we may have additional comments. Form 10 -Q for Fiscal Quarter Ended September 30, 2014 Note 11. Commitments and Contingent Liabilities, page 19 1. We note your response to comment 2 i n our letter dated November 7, 2014. While we appreciate that you began including the nature of the Greek Labor Cases in your footnote disclosures, there is a concern regarding compliance with ASC 450 -20-50-3 and ASC 450 - 20-50-4. Please expand your concl usion that you do not expect the outcome of this matter to material ly impact your results of operations to your financial position and cash flows. If it is reasonably possible that the amount of loss in excess of accrual could materially impact your results of operations, financial position, and/or cash flows; please disclose the range of reasonably possible loss in excess of accrual or disclose that you are unable to make such an estimate. Please provide us with the footnote disclosure you intend to includ e in your fiscal year 2014 Form 10 -K in response to this comment. Ms. Thompson Goodyear Tire & Rubber Co November 25 , 2014 Page 2 You may contact Tracey Houser , Staff Accountant, at (202) 551 -3736, or in her absence, Melissa N. Rocha, Senior Assistant Chief Accountant , at (202) 551 -3854 , or me at (202) 551 - 3355, if you have questions regarding comments on the financial statements and related matters. Sincerely, /s/ Terence O ’Brien Terence O’Brien Accounting Branch Chief