SEC Comment Letter 0000000000-23-011064 to GOODYEAR TIRE & RUBBER CO /OH/ (GT)
GOODYEAR TIRE & RUBBER CO /OH/
Date: Oct. 9, 2023 · CIK: 0000042582 · Accession: 0000000000-23-011064
AI Filing Summary & Sentiment
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File numbers found in text: 001-01927
Letter
United States securities and exchange commission logo October 6, 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 Form 10-Q for the Quarterly Period Ended June 30, 2023 Response dated October 3, 2023 File No. 001-01927 Dear Christina L. Zamarro: We have reviewed your October 3, 2023 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 19, 2023 letter. Form 10-Q for the Quarterly Period Ended June 30, 2023 Notes to Consolidated Financial Statements, page 7 1.We note your response and your conclusion that at June 30, 2023, after evaluating macroeconomic conditions, your market capitalization and your results of operations, that it was not more likely than not that the fair values of our goodwill or indefinite-lived intangible assets were less than their respective carrying values and, therefore, you did not have any impairment. We also noted, to some extent, deterioration in your operating results (i.e., decreasing income before income taxes) and cash flows from operations between the interim and annual reporting periods. Please refer to Item 303(b)(3) of Regulation S-K and expand your disclosures in future filings to address the following:
• provide a more detailed description of the key assumptions you used to estimate fair
FirstName LastNameChristina L. Zamarro Comapany NameThe Goodyear Tire & Rubber Company October 6, 2023 Page 2 FirstName LastName Christina L. Zamarro The Goodyear Tire & Rubber Company October 6, 2023 Page 2 value, including how the key assumptions were determined;
• discuss the degree of uncertainty associated with the key assumptions, including material changes in the key assumptions during the periods presented;
• describe the potential events and/or changes in circumstances that could result in additional impairment charges; and
• disclose the percentage by which your estimated fair value exceeds your carrying value as of the date of your most recent impairment test.
Please contact Beverly Singleton at 202-551-3328 or Melissa Gilmore at 202-551-3777 if you have questions regarding comments on the financial statements and related matters. Sincerely, Division of Corporation Finance Office of Manufacturing
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United States securities and exchange commission logo
October 6, 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
Form 10-Q for the Quarterly Period Ended June 30, 2023
Response dated October 3, 2023
File No. 001-01927
Dear Christina L. Zamarro:
We have reviewed your October 3, 2023 response to our comment letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our September 19, 2023
letter.
Form 10-Q for the Quarterly Period Ended June 30, 2023
Notes to Consolidated Financial Statements, page 7
1.We note your response and your conclusion that at June 30, 2023, after evaluating
macroeconomic conditions, your market capitalization and your results of operations, that
it was not more likely than not that the fair values of our goodwill or indefinite-lived
intangible assets were less than their respective carrying values and, therefore, you did not
have any impairment. We also noted, to some extent, deterioration in your operating
results (i.e., decreasing income before income taxes) and cash flows from operations
between the interim and annual reporting periods. Please refer to Item 303(b)(3) of
Regulation S-K and expand your disclosures in future filings to address the following:
• provide a more detailed description of the key assumptions you used to estimate fair
FirstName LastNameChristina L. Zamarro
Comapany NameThe Goodyear Tire & Rubber Company
October 6, 2023 Page 2
FirstName LastName
Christina L. Zamarro
The Goodyear Tire & Rubber Company
October 6, 2023
Page 2
value, including how the key assumptions were determined;
• discuss the degree of uncertainty associated with the key assumptions, including material
changes in the key assumptions during the periods presented;
• describe the potential events and/or changes in circumstances that could result in
additional impairment charges; and
• disclose the percentage by which your estimated fair value exceeds your carrying value
as of the date of your most recent impairment test.
Please contact Beverly Singleton at 202-551-3328 or Melissa Gilmore at 202-551-3777 if
you have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Manufacturing