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SEC Comment Letter for GOODYEAR TIRE & RUBBER (GT) — Mar 23, 2016

GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: March 23, 2016 · CIK: 0000042582 · Accession: 0000000000-16-069470

AI Filing Summary & Sentiment

Sentiment
Urgency
Document Type
Confidence
SEC Posture
Company Posture

Summary

Reasoning

Referenced dates: March 9, 2016

Date
March 23, 2016
Author
/s/ Cecilia Blye
Form
UPLOAD
Company
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)

Letter

Mailstop 4628 March 23, 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 December 31, 2015 Filed February 9, 2015 File No. 1 -01927

Dear Mr. Kramer:

We refer you to our comment letter dated March 9, 2016, regarding business contacts with Sudan and Syria. We have completed our review of this subject matter. 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 fili ng 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 laws 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/ Cecilia Blye

Show Raw Text
Mailstop 4628
March 23, 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 December 31, 2015
Filed February 9, 2015
File No. 1 -01927

Dear Mr. Kramer:

We refer you to our comment letter dated March 9, 2016, regarding business contacts
with Sudan and Syria.  We have completed our review of this subject matter.  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 fili ng 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 laws 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/ Cecilia Blye

Cecilia Blye, Chief
Office of Global Security Risk

cc:  Pamela Long
  Assistant Directo r
 Division of Corporation Finance