November 20, 2018

Darren Wells
Chief Financial Officer
GOODYEAR TIRE & RUBBER CO /OH/
200 Innovation Way
Akron, Ohio 44316-0001

       Re: GOODYEAR TIRE & RUBBER CO /OH/
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed February 8, 2018
           File No. 001-01927

Dear Mr. Wells:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K for Fiscal Year Ended December 31, 2017

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Critical Accounting Policies
Deferred Tax Asset Valuation Allowance and Uncertain Income Tax Positions, page
34

1.    Considering the significance of the $749 million of foreign tax credits
deferred tax assets
      to your consolidated financial statements and your conclusion that your
undistributed
      foreign earnings are indefinitely reinvested, please expand your
disclosures to clearly
      explain to investors the specific source of foreign income you are
relying on to fully
      realize your foreign tax credits deferred tax assets. Please refer to
comment 4 in our letter
      dated December 22, 2016, and comment 2 in our letter dated February 3,
2017, along with
      your corresponding letters dated January 9, 2017, and February 7, 2017,
respectively.
 Darren Wells
GOODYEAR TIRE & RUBBER CO /OH/
November 20, 2018
Page 2

       In closing, 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.

       You may contact Tracey Houser, Staff Accountant, at (202) 551-3736, or
Terence
O'Brien, Accounting Branch Chief, at (202) 551-3355, with any questions.



                                                          Sincerely,
FirstName LastNameDarren Wells
                                           Division of Corporation Finance
Comapany NameGOODYEAR TIRE & RUBBER CO /OH/
                                           Office of Manufacturing and
November 20, 2018 Page 2                   Construction
FirstName LastName