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June 9, 2010

VIA EDGAR and FACSIMILE (703) 813-6968

Mr. Terence O’Brien

Branch Chief

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-4631

    Re:

    The Goodyear Tire & Rubber Company

Form 10-K for the fiscal year ended December 31, 2009

Filed February 19, 2010

File No. 1-1927

Dear Mr. O’Brien:

     This letter is in response to the letter, dated May 21, 2010 (the “Comment Letter”), from you,
on behalf of the Division of Corporation Finance of the U.S. Securities and Exchange Commission
(the “Commission”), to Mr. Darren R. Wells, Executive Vice President and Chief Financial Officer of
The Goodyear Tire & Rubber Company (“Goodyear,” the “Company” and “we,” “us” or “our”), with
respect to the above-referenced filing.

     For the convenience of the Commission staff, we have repeated each of your comments in italics
before our response. Each numbered paragraph herein corresponds to the same numbered paragraph in
the Comment Letter.

     The Company respectfully submits the following information in response to the Comment Letter.

Form 10-K for the year ended December 31, 2009

Management’s Discussion and Analysis, page 28

Liquidity and Capital Resources, page 45

    1.

    In your response to comment 4, you discuss how you have disclosed specific
items relating to your Venezuelan subsidiary when they are material to a broader
discussion of your Latin American Tire segment or to overall liquidity. Please expand
MD&A in future filings to provide a more comprehensive discussion of your Venezuelan
operations that provides a greater level of information about the monetary assets and
liabilities that are exposed to exchange rate changes and the

    sensitivity of your sales and cost of sales to future currency changes. Disclose the
specific amount of bolivar-denominated monetary assets and liabilities as of each
balance sheet date and provide a break-out of the amounts being remeasured at each
exchange rate. Provide this disclosure at a reasonably detailed level; for example,
disclose amounts for cash and accounts receivable. Disclose the amount of sales and
costs of sales for Goodyear Venezuela and separately disclose the amounts denominated in
bolivar fuerte and the U.S. dollar. Please provide us an example of future disclosure.

In future filings, the following additional underlined disclosure related to our Venezuelan
operations will appear in our Management’s Discussion and Analysis — Liquidity and Capital
Resources section:

“Effective January 1, 2010, Venezuela’s economy was considered to be highly inflationary under U.S.
generally accepted accounting principles. Accordingly, the U.S. dollar was determined to be the
functional currency of our Venezuelan subsidiary. All gains and losses resulting from the
remeasurement of its financial statements are determined using official exchange rates. On January
8, 2010, the Venezuelan government announced the devaluation of the bolivar fuerte against the U.S.
dollar and the establishment of a two-tier exchange structure for essential and non-essential
goods. For essential goods the exchange rate is 2.6 bolivares fuertes to the U.S. dollar and
for non-essential goods the exchange rate is 4.3 bolivares fuertes to the U.S. dollar. As a
result, we recorded a loss of $110 million in the first quarter of 2010 in connection with the
remeasurement of our balance sheet to reflect the devaluation.

If in the future we convert bolivares fuertes at a rate other than the official exchange rates, we
may realize additional gains or losses that would be recorded in the statement of operations.
At June 30, 2010, we had bolivar fuerte denominated monetary assets of $___
 million which consisted primarily of $___ million of cash and $___
 million of accounts receivable, and bolivar fuerte denominated monetary liabilities of $___ million which consisted primarily of $___ million
of accounts payable — trade, $___ million of income taxes payable and $___ million of
compensation and benefits. At December 31, 2009, we had bolivar fuerte denominated monetary assets
of $___ million which consisted primarily of $___ million of cash and $___ million of accounts
receivable and bolivar fuerte denominated monetary liabilities of $___ million which consisted
primarily of $___ million of accounts payable — trade, $___ million of income taxes payable and
$___ million of compensation and benefits. All monetary assets and liabilities were remeasured at
4.3 bolivares fuertes to the U.S. dollar at June 30, 2010, and were translated at 2.15 bolivares
fuertes to the U.S. dollar at December 31, 2009.

Goodyear Venezuela’s sales were X% and X% of our net sales for the three months ended June 30,
2010 and 2009, respectively, and were X% and X% of our net sales for the six months ended June 30,
2010 and 2009, respectively. Goodyear Venezuela’s operating income was X% and X% of our segment
operating income for the three and six months ended June 30, 2010. For the three and six months
ended June 30, 2009, we had a segment operating loss and, therefore, the percentage is not
applicable. Goodyear Venezuela’s sales are bolivar fuerte denominated and cost of goods sold are
approximately X% bolivar fuerte denominated and approximately X% U.S. dollar denominated. A 10%
increase/(decrease) in each of the official exchange rates would

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decrease/(increase) Goodyear Venezuela’s sales and cost of goods sold on an annual basis by
approximately $___ million and $___ million, respectively.

Goodyear Venezuela contributed a significant portion of Latin American Tire’s sales and operating
income in 2009. The devaluation of the bolivar fuerte and weak economic conditions are expected to
adversely impact Latin American Tire’s current year segment operating income by $50 million to $75
million as compared to 2009. In response to the devaluation of the bolivar fuerte and weak
economic conditions, we continue to evaluate the need to adjust prices for our products while
remaining competitive. Our pricing policies take into account factors such as fluctuations in raw
material cost, production cost, market demand and adherence to government price controls. For
discussion of the risks related to our international operations, including Venezuela, see “Item 1A.
Risk Factors” in our 2009 Form 10-K.”

    2.

    In a response to us, you state you have not used the parallel market to settle
U.S. dollar-denominated accounts payable, intercompany amounts or other balances. In
future filings please provide a discussion of amounts you have settled at the official
rate during the periods presented or, if no amounts have been settled during this time,
discuss the most recent settlements. Disclose the amount of bolivar fuerte pending
government approval for settlement at the official rate (and which official rate) and
the length of time the request(s) have been pending. Discuss the implications of the
current exchange rate system for your operations and cash flows. Please provide us an
example of future disclosure.

In future filings, the following additional underlined disclosure related to our Venezuelan
operations will appear in our Management’s Discussion and Analysis — Liquidity and Capital
Resources section:

“During the six month period ended June 30, 2010 and 2009, Goodyear Venezuela settled $___
million and $___ million, respectively, of U.S. dollar denominated intercompany payables and
accounts payable — trade, approximately X% and X% of which were settled at the essential goods
rate of 2.6 bolivares fuertes to the U.S. dollar and at the official rate of 2.15 bolivares fuertes
to the U.S. dollar, respectively. At June 30, 2010, pending settlements of U.S. dollar denominated
liabilities were approximately $___ million of which approximately $___ million are expected to be
settled at 2.6 bolivares fuertes to the U.S. dollar and approximately $___ million are expected to
be settled at 4.3 bolivares fuertes to the U.S. dollar. At June 30, 2010, approximately $___
million of the requested settlements were pending up to 180 days, $___ million were pending from
180 to 360 days and $___ million were pending over one year of which approximately $___ million
represented dividends. Currency exchange controls in Venezuela continue to limit our ability to
remit funds from Venezuela.”

In addition, in future filings, the following additional underlined disclosure related to our
Venezuelan operations will appear in our Management’s Discussion and Analysis — Liquidity and
Capital Resources section:

“Our ability to service debt and operational requirements are also dependent, in part, on the
ability of our subsidiaries to make distributions of cash to various other entities in our
consolidated group, whether in the form of dividends, loans or otherwise. In certain countries

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where we operate, such as Venezuela, transfers of funds into or out of such countries by way of
dividends, loans, advances or payments to third-party or affiliated suppliers are generally or
periodically subject to various restrictions, such as obtaining approval from the foreign
government and/or currency exchange board before net assets can be transferred out of the country.
In addition, certain of our credit agreements and other debt instruments restrict the ability of
foreign subsidiaries to make distributions of cash. Thus, we would have to repay and/or amend
these credit agreements and other debt instruments in order to use this cash to service our
consolidated debt. Because of the inherent uncertainty of overcoming these restrictions, we do not
consider the net assets of our subsidiaries, including Goodyear Venezuela, that are subject
to such restrictions to be integral to our liquidity or readily available to service our debt and
operational requirements.”

    3.

    In future filings, please discuss your plans to manage the challenges presented
by the current exchange rate system. For example, disclose changes in business
practices or policies that have occurred or are anticipated to occur in response to the
devaluation and the hyperinflationary environment.

Please see the additional underlined disclosure in the last paragraph of our response to comment 1
that will be included in future filings.

    4.

    In a separate letter dated April 30, 2010, you provided us with summarized
financial information for Goodyear Venezuela. Since it does not appear you have
requested confidential treatment pursuant to Rule 83 for the information, please upload
this information to EDGAR as correspondence.

In response to your request, we are providing below the summarized financial information for
Goodyear Venezuela that was previously provided to you supplementally. We included the quarter
ended March 31, 2010 for comparative purposes.

    At

    At

    ($ in millions)

    December 31, 2009

    March 31, 2010

    Total Assets

    $
    452

    $
    286

    Total Liabilities

    $
    221

    $
    157

    Net Assets

    $
    231

    $
    129

    For the

    For the

    For the quarter

    year ended

    year ended

    ended

    ($ in millions)

    December 31, 2008

    December 31, 2009

    March 31, 2010

    Net Sales

    $
    297

    $
    384

    $
    43

    Operating Income

    $
    78

    $
    143

    $
    6

Note 3. Other Expense, page 75

    5.

    We have read your response to comment 5 in our letter dated April 23, 2010.
Please provide the clarifying language contained in your response in future filings as
applicable.

-4-

In future filings, we will include the clarifying language contained in our response dated April
30, 2010, as applicable.

* * * *

In addition, our response to comment 1 set forth in our letter to you, dated May 18, 2010, is
restated in full below in order to correct arithmetic errors made in calculating the percentages
included in our original response.

    1.

    We note from your disclosure on pages 2, 3, 5-6, 20, 22, and elsewhere that you
continue to operate in Latin America, the Middle East, and Africa, regions generally
understood to include Cuba, Iran, Syria, and Sudan. As you know, those countries are
identified by the State Department as state sponsors of terrorism, and are subject to
U.S. economic sanctions and export controls. Please provide us with information
regarding your contacts with Cuba, Iran, Syria, and Sudan since your letter to the
staff dated August 24, 2006. Your response should describe any products, components,
equipment, technology, software or services you have provided into any of those
countries, directly or indirectly, since your letter dated August 24, 2006, and any
agreements, commercial arrangements, or other contacts you have had with the
governments of those countries or entities controlled by those governments since that
time.

It is the policy of the Company to comply in all respects with all applicable U.S. export and
foreign trade controls. To support this policy, the Company’s computer systems in North America
prevent a user from entering any sales to Cuba, Iran, Syria or Sudan on the Company’s order-to-cash
system. Moreover, the Company’s compliance efforts in the area of U.S. export and foreign trade
controls are designed to help ensure that sales and other personnel worldwide understand applicable
U.S. export and foreign trade controls and new developments in those controls.

The Company and its subsidiaries have no operations or offices in Cuba and have no agreements,
commercial arrangements or other contacts with the government of Cuba or entities controlled by the
government of Cuba, nor are we aware of any sales of products or services, directly or indirectly,
into Cuba by the Company or its subsidiaries. From 1946 to 1960, the Company had a subsidiary in
Cuba, Goodyear de Cuba, S.A. Productos de Goma, that operated a factory in that country. In 1960,
the government of Cuba seized and confiscated all of the assets of that subsidiary.

The Company and its subsidiaries also have no operations or offices in Iran, Syria or Sudan. While
the foreign subsidiaries of U.S.-based companies are not prohibited from doing business with
parties in Iran, Syria or Sudan, we are not aware of any sales by the Company or its subsidiaries
of products or services to parties in Syria, Iran or Sudan since 2008 and, in the case of Syria,
since 2006.

Certain of the Company’s foreign subsidiaries made a small amount of direct sales to parties in
Iran and Sudan in 2007 and 2008. With respect to Iran, certain of the Company’s foreign
subsidiaries had sales of commercial aircraft tires and tubes and retreading services in 2007 and

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2008 of $902,000 and $711,000 (substantially less than 0.01% of the Company’s consolidated net
sales in each of those years), respectively, including sales to a government-owned commercial
airline company. With respect to Sudan, a foreign subsidiary of the Company had sales of consumer,
commercial truck, earthmover and farm tires, tubes and flaps in 2007 and 2008 of $141,200 and $600
(substantially less than 0.001% of the Company’s consolidated net sales in each of those years),
respectively, including sales to a government-owned sugar company.

In addition to the sales by certain foreign subsidiaries described above, certain products of
foreign subsidiaries may reach Iran, Syria or Sudan through sales to unaffiliated third parties.
For example, we are aware that:

    •

    A foreign subsidiary of the Company made sales to unaffiliated third parties based
in Dubai, United Arab Emirates, a portion of which that foreign subsidiary believes
were destined for Iran. In 2007, 2008 and 2009, these sales totaled $21,330,000,
$15,871,000 and $11,700,000 (0.1%, 0.08% and 0.07% of the Company’s consolidated net
sales), respectively, and consisted of consumer, commercial truck, earthmover and farm
tires, tubes and flaps. In May