[Letterhead of Covington & Burling]



                                                   December 9, 2005



The Goodyear Tire & Rubber Company
1144 East Market Street
Akron, Ohio 44316-0001

Ladies and Gentlemen:

        We have acted as counsel to The Goodyear Tire & Rubber Company, an Ohio
corporation (the "Company"), in connection with the filing by the Company of a
registration statement on Form S-1 (File No. 333-127918), as amended to the date
hereof (the "Registration Statement"), with the Securities and Exchange
Commission under the Securities Act of 1933, as amended, relating to the resale
by certain selling securityholders of (i) up to $350,000,000 aggregate principal
amount of the Company's 4.00% Convertible Senior Notes due 2034 (the "Notes")
issued under the Indenture, dated as of July 2, 2004 (the "Indenture"), among
the Company and Wells Fargo Bank, N.A., as trustee, and (ii) shares of the
Company's common stock, without par value, issuable upon conversion of the
Notes.

        We have reviewed such corporate records, certificates and other
documents, and such questions of law, as we have considered necessary or
appropriate for the purposes of this opinion. We have assumed that all
signatures are genuine, that all documents submitted to us as originals are
authentic and that all copies of documents submitted to us conform to the
originals, and that the Notes have been duly authenticated by the Trustee for
the Notes as provided in the Indenture for the Notes. We have assumed further
that the Company is duly organized, validly existing and in good standing under
the laws of the state in which it is organized and that it has the requisite
power, authority and legal right to execute, deliver and perform the Notes. We
have assumed further that the Company has duly authorized, executed and
delivered the Indenture and the Notes.

        We have relied as to certain matters on information obtained from public
officials, officers of the Company, and other sources believed by us to be
responsible.

        Based upon the foregoing, and subject to the qualifications set forth
herein, we are of the opinion that the Notes constitute valid and binding
obligations of the Company, enforceable against the Company in accordance with
their terms, subject to bankruptcy, insolvency,



December 9, 2005
Page 2

fraudulent transfer, reorganization, moratorium and other laws of general
applicability relating to or affecting creditors' rights and to general equity
principles.

        The foregoing opinion is subject to the qualifications that we express
no opinion as to (i) waivers of defenses or statutory or constitutional rights
or waivers of unmatured claims or rights, (ii) rights to indemnification,
contribution or exculpation to the extent that they purport to indemnify any
party against, or release or limit any party's liability for, its own breach or
failure to comply with statutory obligations, or to the extent such provisions
are contrary to public policy, or (iii) rights to collection or liquidated
damages or penalties on overdue or defaulted obligations.

        We are members of the bar of the State of New York. We do not express
any opinion herein on any laws other than the law of the State of New York and
the Federal law of the United States of America.

        We hereby consent to the filing of this opinion as Exhibit 5.1 to the
Registration Statement and to the reference to our firm under the heading "Legal
Matters" in the Prospectus contained in the Registration Statement. In giving
such consent, we do not thereby admit that we are in the category of persons
whose consent is required under Section 7 of the Securities Act.

                                                      Very truly yours,

                                                      /s/ Covington & Burling

                                                      Covington & Burling