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SEC Company Response from GOODYEAR TIRE & RUBBER (GT) — Mar 1, 2010

GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: March 1, 2010 · CIK: 0000042582 · Accession: 0000950123-10-019196

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File numbers found in text: 333-164632

Date
March 1, 2010
Author
By
Form
CORRESP
Company
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)

Letter

Division of Corporation Finance Attention: Pamela A. Long The Goodyear Tire & Rubber Company Registration Statement on Form S-4 File No. 333-164632

Re:

Dear Ms. Long:

We hereby request that the above-referenced Registration Statement be declared effective by the Commission on March 2, 2010 at 5:00 p.m. (local time) or as soon as practical thereafter.

Through this letter, we hereby acknowledge that:

•

should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the company may not assert the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Should you have any questions regarding the foregoing, please call the undersigned at (330) 796-2408 or Daniel Young at (330) 796-4141.

Very truly yours,
By:

Show Raw Text
CORRESP
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corresp

[Letterhead of The Goodyear Tire & Rubber Company]

March 1, 2010

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E., Mail Stop 4631

Washington, D.C. 20549

Attention: Pamela A. Long

    Re:

    The Goodyear Tire & Rubber
Company

Registration Statement on Form S-4

File No. 333-164632

Dear Ms. Long:

     We hereby request that the above-referenced Registration Statement be declared effective by
the Commission on March 2, 2010 at 5:00 p.m. (local time) or as soon as practical thereafter.

     Through this letter, we hereby acknowledge that:

    •

    should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the company from its full
responsibility for the adequacy and accuracy of the disclosure in the filing; and

    •

    the company may not assert the declaration of effectiveness as a defense in any
proceeding initiated by the Commission or any person under the federal securities
laws of the United States.

     Should you have any questions regarding the foregoing, please call the undersigned at (330)
796-2408 or Daniel Young at (330) 796-4141.

    Very truly yours,

    By:

    /s/ David L. Bialosky

    David L. Bialosky

    Senior Vice President, General Counsel and Secretary