THE GOODYEAR TIRE & RUBBER COMPANY
Akron, Ohio 44316-0001
VIA EDGAR
March 30, 2021
Mr. Sergios Chinos
Staff Attorney
Office of Manufacturing and Construction
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E
Washington, D.C. 20549-7010
Re: | The Goodyear Tire & Rubber Company |
Registration Statement on Form S-4
File No. 333-254482
Ladies and Gentlemen:
In accordance with Rule 461 promulgated under the Securities Act of 1933, as amended, The Goodyear Tire & Rubber Company (the “Company”) hereby respectfully requests acceleration of the effectiveness of the Company’s Registration Statement on Form S-4 (File No. 333-254482), in connection with the proposed transaction involving the Company, Vulcan Merger Sub Inc. and Cooper Tire & Rubber Company, to 4:00 p.m., Eastern Time, on April 1, 2021, or as soon thereafter as is practicable.
Please contact David S. Huntington, of Paul, Weiss, Rifkind, Wharton & Garrison LLP, counsel to the Company, at (212) 373-3124, as soon as the Registration Statement has been declared effective, or if you have any other questions or concerns regarding this matter.
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Respectfully submitted, | ||
THE GOODYEAR TIRE & RUBBER COMPANY | ||
By: | /s/ Daniel T. Young | |
Daniel T. Young | ||
Secretary and Associate General Counsel |
cc: | David Phillips – The Goodyear Tire & Rubber Company |
Stephen Zamansky – Cooper Tire & Rubber Company
Scott A. Barshay – Paul, Weiss, Rifkind, Wharton & Garrison LLP
Kyle T. Seifried – Paul, Weiss, Rifkind, Wharton & Garrison LLP
David S. Huntington – Paul, Weiss, Rifkind, Wharton & Garrison LLP
James P. Dougherty – Jones Day
Benjamin L. Stulberg – Jones Day