SecProbe.io

Mailstop 4628
March 9 , 2016

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

Re: The Goodyear Tire & Rubber Company
 Form 10 -K for the Fiscal Year Ended December 31, 2015
Filed February 9, 2016
File No. 1 -01927

Dear Mr. Kramer:

We have limited our review of your filing to your contacts with countries that have been
identified as state sponsors of terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the Assistant Director group with respect
to other issues.   In our comments, we ask you to p rovide us with information so we may better
understand your disclosure.

Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comments, we may have additional comments.

General

1. We note a press release dated November 6, 2015 on the website of Titan Int ernational, Inc.,
announcing that the company entered into a licensing agreement with you to distribute and
sell Goodyear -brand farm tires in countries including Sudan and Syria.  As you are aware,
Sudan and Syria are designated by the State Department as state sponsors of terrorism, and
are subject to U.S. economic sanctions and export controls.  Your Form 10 -K does not
include disclosure about contacts with Sudan or Syria.  Please provide us with information
regarding contacts with Sudan and Syria since y our letter to us dated May 3, 2013.   You
should describe any products, technology or services you have provided into Sudan and
Syria, directly or indirectly, and any agreements, commercial arrangements or other
contacts you have had with the governments of  Sudan and Syria or entities they control.

Richard J. Kramer
The Goodyear Tire & Rubber Company
March 9 , 2016
Page 2

 2. Please discuss the materiality of any contacts with Sudan and Syria you describe in
response to the comment above, and whether the contacts constitute a material
investment risk for your security holders.   You sh ould address materiality in quantitative
terms, including the approximate dollar amounts of any revenues, assets and liabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.   Also, address materiality i n terms of qualitative factors that a reasonable investor
would deem important in making an investment decision, including the potential impact
of corporate activities upon a company’s reputation and share value.   As you know,
various state and municipal g overnments, universities and other investors have proposed
or adopted divestment or similar initiatives regarding investment in companies that do
business with U.S. -designated state sponsors of terrorism.   You should address the
potential impact of the inv estor sentiment evidenced by such actions directed toward
companies that have operations associated with Sudan and Syria.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that t he filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accu racy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commissi on or any person under the federal securities laws of the United States.

You may contact Pradip Bhaumik, Special Counsel, at (202) 551 -3333 or me at (202)
551-3470 if you have any questions about the comments or our review.

Sincerely,

 /s/ Cecilia Blye

Cecilia Bly e, Chief
Office of Global Security Risk

cc:  Pamela Long
  Assistant Director
 Division of Corporation Finance