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                          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