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September 19, 2023
Christina L. Zamarro
Chief Financial Officer
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, 2022
Filed February 13, 2023
Form 10-Q for the Quarterly Period Ended June 30, 2023
Filed August 3, 2023
File No. 001-01927
Dear Christina L. Zamarro:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following 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 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.
Form 10-Q for the Quarterly Period Ended June 30, 2023
Notes to Consolidated Financial Statements, page 7
1.We note in your recent 10-K disclosures that at October 31, 2022, after considering the
results of your most recent quantitative annual testing for each reporting unit and
indefinite-lived intangible asset, results of valuations related to the acquisition of Cooper
Tire, the capital markets environment, macroeconomic conditions, tire industry
competition and trends, our results of operations, and other factors, you concluded that it
was not more likely than not that the fair values of your reporting units or indefinite-lived
intangible assets were less than their respective carrying values and, therefore, did not
perform a quantitative analysis.  We further note in your 10-Q for the period ended June
30, 2023, we note that your results of operations during the second and first six months of
2023 reflected a difficult macroeconomic environment including a softening

 FirstName LastNameChristina L. Zamarro
 Comapany NameThe Goodyear Tire & Rubber Company
 September 19, 2023 Page 2
 FirstName LastName
Christina L. Zamarro
The Goodyear Tire & Rubber Company
September 19, 2023
Page 2
industry demand, lower volumes, inflationary impacts as well as other factors and that
your net book value currently exceeds your market capitalization.  However, we noted no
revisions to your disclosures related to goodwill under critical accounting estimates in
MD&A in subsequent quarterly filings that address these factors. Please revise future
filings to address if and how these factors impacted your determination to test
goodwill for impairment as of an interim date and, if not, explain why not. Please also
revise future filings to explain if and how you consider market capitalization in
determining the estimated fair values of reporting units. Refer to ASC 350-20-35-
3C, ASC 350-20-35-22 to 24, and ASC 350-20-35-30.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Beverly Singleton at (202) 551-3328 or Melissa Gilmore at (202) 551-
3777 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing