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                               September 19, 2023

       Christina L. Zamarro
       Chief Financial Officer
       The Goodyear Tire & Rubber Company
       200 Innovation Way
       Akron, Ohio 44316-0001

                                                        Re: The Goodyear Tire &
Rubber Company
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 13,
2023
                                                            Form 10-Q for the
Quarterly Period Ended June 30, 2023
                                                            Filed August 3,
2023
                                                            File No. 001-01927

       Dear Christina L. Zamarro:

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

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-Q for the Quarterly Period Ended June 30, 2023

       Notes to Consolidated Financial Statements, page 7

   1.                                                   We note in your recent
10-K disclosures that at October 31, 2022, after considering the
                                                        results of your most
recent quantitative annual testing for each reporting unit and
                                                        indefinite-lived
intangible asset, results of valuations related to the acquisition of Cooper
                                                        Tire, the capital
markets environment, macroeconomic conditions, tire industry
                                                        competition and trends,
our results of operations, and other factors, you concluded that it
                                                        was not more likely
than not that the fair values of your reporting units or indefinite-lived
                                                        intangible assets were
less than their respective carrying values and, therefore, did not
                                                        perform a quantitative
analysis. We further note in your 10-Q for the period ended June
                                                        30, 2023, we note that
your results of operations during the second and first six months of
                                                        2023 reflected a
difficult macroeconomic environment including a softening
 Christina L. Zamarro
The Goodyear Tire & Rubber Company
September 19, 2023
Page 2
         industry demand, lower volumes, inflationary impacts as well as other
factors and that
         your net book value currently exceeds your market capitalization.
However, we noted no
         revisions to your disclosures related to goodwill under critical
accounting estimates in
         MD&A in subsequent quarterly filings that address these factors.
Please revise future
         filings to address if and how these factors impacted your
determination to test
         goodwill for impairment as of an interim date and, if not, explain why
not. Please also
         revise future filings to explain if and how you consider market
capitalization in
         determining the estimated fair values of reporting units. Refer to ASC
350-20-35-
         3C, ASC 350-20-35-22 to 24, and ASC 350-20-35-30.
       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 Beverly Singleton at (202) 551-3328 or Melissa Gilmore at
(202) 551-
3777 with any questions.



FirstName LastNameChristina L. Zamarro                       Sincerely,
Comapany NameThe Goodyear Tire & Rubber Company
                                                             Division of
Corporation Finance
September 19, 2023 Page 2                                    Office of
Manufacturing
FirstName LastName