SEC Company Response from GOODYEAR TIRE & RUBBER (GT) — Jan 16, 2014
GOODYEAR TIRE & RUBBER CO /OH/ (GT) (CIK 0000042582)
Date: Jan. 16, 2014 · CIK: 0000042582 · Accession: 0001193125-14-012767
AI Filing Summary & Sentiment
Reasoning
Letter
VIA EDGAR Division of Corporation Finance Re: The Goodyear Tire & Rubber Company Form 10-K for fiscal year ended December 31, Filed February 12, 2013 File No. 1-1927
Dear Ms. Rocha:
This letter is in response to the letter, dated January 15, 2014 (the “Comment Letter”), from you, on behalf of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”), to Ms. Laura K. Thompson, 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 your comment in italics before our response. The Company respectfully submits the following information in response to the Comment Letter.
Form 10-K for fiscal year ended December 31, 2012
Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 27
1. We note your proposed revised disclosure to our prior comment that includes an allocation of pension costs between cost of goods sold and selling, administrative and general expense on a consolidated basis. In future filings, please ensure your results of operations section of MD&A discusses the impact of your pensions on the above line items on a consolidated basis as well as operating income on a segment basis, including discussion of the factors contributing to any material year over year changes in pension costs.
In future filings, we will include the disclosure requested by your comment in the results of operations section of MD&A, including discussion of the factors contributing to any material year over year changes in pension costs.
* * * *
In connection with our response to the Comment Letter, the Company hereby acknowledges that:
•
the Company is responsible for the adequacy and accuracy of the disclosure in the filing;
•
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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.
Please direct any questions, comments and advice of the Commission staff to the undersigned at 330-796-2775 (fax: 330-796-2338).
Respectfully submitted,
THE GOODYEAR TIRE & RUBBER COMPANY
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CORRESP 1 filename1.htm CORRESP THE GOODYEAR TIRE & RUBBER COMPANY Akron, Ohio 44316-0001 January 16, 2014 VIA EDGAR Ms. Melissa N. Rocha Senior Assistant Chief Accountant U.S. Securities and Exchange Commission Division of Corporation Finance 100 F Street, NE Washington, D.C. 20549-7010 Re: The Goodyear Tire & Rubber Company Form 10-K for fiscal year ended December 31, 2012 Filed February 12, 2013 File No. 1-1927 Dear Ms. Rocha: This letter is in response to the letter, dated January 15, 2014 (the “Comment Letter”), from you, on behalf of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”), to Ms. Laura K. Thompson, 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 your comment in italics before our response. The Company respectfully submits the following information in response to the Comment Letter. Form 10-K for fiscal year ended December 31, 2012 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 27 1. We note your proposed revised disclosure to our prior comment that includes an allocation of pension costs between cost of goods sold and selling, administrative and general expense on a consolidated basis. In future filings, please ensure your results of operations section of MD&A discusses the impact of your pensions on the above line items on a consolidated basis as well as operating income on a segment basis, including discussion of the factors contributing to any material year over year changes in pension costs. In future filings, we will include the disclosure requested by your comment in the results of operations section of MD&A, including discussion of the factors contributing to any material year over year changes in pension costs. * * * * In connection with our response to the Comment Letter, the Company hereby acknowledges that: • the Company is responsible for the adequacy and accuracy of the disclosure in the filing; • staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; 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. Please direct any questions, comments and advice of the Commission staff to the undersigned at 330-796-2775 (fax: 330-796-2338). Respectfully submitted, THE GOODYEAR TIRE & RUBBER COMPANY By: /s/ Richard J. Noechel Richard J. Noechel Vice President and Controller cc: Thomas D’Orazio, U.S. Securities and Exchange Commission Laura K. Thompson, The Goodyear Tire & Rubber Company - 2 -