TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo March 23, 2022 Dan Young Secretary and Associate General Counsel Goodyear Tire & Rubber Co. 200 Innovation Way Akron, Ohio 44316-0001 Re: Goodyear Tire & Rubber Co. Registration Statement on Form S-4 Filed March 17, 2022 File No. 333-263635 Dear Mr. Young: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Gregory Herbers at 202-551-8028 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: David Engvall