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                                             July 2, 2007




SENT VIA CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7160 3901 9842 8970 7595


Associate Administrator for Enforcement
NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
1200 New Jersey Avenue, SE
West Building
Washington, D.C. 20590

Gentlemen:

        Cooper Tire & Rubber Company has decided that a defect which relates to motor
vehicle safety exists in ninety-one thousand seven hundred forty-seven (91,747) tires as
set forth in the attached Defect and Noncompliance Information Report dated June 28,
2007.

       These tires are being voluntarily recalled.

        A copy of this letter, with attachments, is being faxed to the Office of Defects
Investigation (ODI) for review by OD1 of the proposed owner notification letters pursuant
to 49 CFR Section 573.6(~)(10). We are asking OD1 to approve the sample owner
letters. Hard copy will follow. Unless advised otherwise by ODI, owner notification will
begin July 10, 2007 Three copies of the appropriate notification to dealers and
customers are attached as exhibits in response to Item 9 of the Defect and
Noncompliance Information Report.

     Our envelope format for owner recall notification letters as required under 49
CFR 577.5(a) has been previously approved by OD!.
      Cooper will provide the required quarterly report on the status of the above-
mentioned campaign.

      Please advise of the NHTSA assigned campaign number

                                            Very truly yours,




JJMlcls
Attachments

cc:   Office of Defects Investigation "NSA-10"
      Department of Transportation
      NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION
      1200 New Jersey Avenue, SE
      West Building
      Washington, D.C. 20590
      Fax Number 2021366-7882
      Attn. Mr. George Person
      Recall Management Regulations
                             COOPER TIRE & RUBBER COMPANY
                     DEFECT AND NONCOMPLIANCE INFORMATION REPORT

DATE: 6/28/07                                                          NHTSA CAMPAIGN NO.

                                                                         COOPER NO. 148

1.   NAME OF MANUFACTURER

     A. Fabricating Manufacturer: Cooper Tire & Rubber Company

     B.   Brand Name or Trademark Owner:

                   BRAND NAME                                           OWNER

                 Dominator Sport A/T                          Cooper Tire & Rubber Company


     POTENTIAL NUMBER OF AFFECTED TIRES (Including a description of the basis for the
     determination of the recall population and a description of how these items differ from similar items not
     included in the recall):

                                 Inclusive Dates                Number of             Estimated Percent
        Description               (week and year)               Potentially           Containing Defect
      (includq size)             of Manufacture                Affectdm                or Noncompliance

     LT265/75R16E             UPWSXDJ 2702 -                      9 1,747                <=2%
     Tubeless Radtal          UPWSXDJ 1305
     tires                    July 7,2002 - Mar 30,2005

     The recall population was based on the entire production population for this SKU and construction



3.    TOTAL UNITS POTENTIALLY AFFECTED:                                 9 1,747


4.    TOTAL ESTIMATED PERCENT CONTAINING DEFECT:                              <= 2%



5.   DESCRIPTION OF DEFECT OR NONCOMPLIANCE (Including brief summary and dctailcd
     description, with graphic aids as necessary, of nature and physical location of the defect or noncompliance).

     The subject tires experienced a hgher rate of property damage claims and adjustments due to belt
     separations. However, after an exhaustive analysis, no design or manufacturing defect was found in th
     subject tires. Despite the absence of evidence of an identifiable design or manufacturing defect, Cooper
     Tire is instituting tlus campaign based upoil the field performance referred to above.
                                 COOPER TIRE & RUBBER COMPANY
                         DEFECT AND NONCOMPLLANCE INFORMATION REPORT


6.    CHRONOLOGY OF ALL PRINCIPLE EVENTS THAT WERE THE BASIS FOR THE
      EXISTENCE OF A SMETY RELATED DEFECT (hcludmg a summary of all warranty claims, field
      service reports, and other mformation, with their dates of receipt):

      On 7/13/06, NHTSA opened a preliminary evaluation into the subject tires based on EWR data; Cooper's
      response was submitted 10/4/06.

      On 12/27/06 NHTSA upgraded the investigation lo an Engineering Analysis. A series of meetings
      between Cooper and NHTSA were conducted to analyze adjustment data as well as review the design and
      manufacturing processes used with regard to the subject tire. The process review included analysis of
      wheel and temperature test data, manufachuing process control data, and forensic field return data. The
      overall conclusion from these analyses was that there was no identifiable manufacturing or design-related
      defect in the subject tires.

      On 6119/07 a follow-up meeting was conducted between NHTSA and Cooper. As a result of that meeting
      and subscqucnt evaluation by the company, Cooper is voluntarily recalling the 9 1,747 tires.


7.    COMPLIANCE TESTING OR OTHER DATA THAT WAS THE BASIS FOR DETERMINING
      THE EXISTENCE OF NONCOMPLIANCE:

      This action was initiated based on EWR data and on internal adjustment and property damage ckum data.


8.    STATEMENT OF MEASURES TO BE TAKEN TO REMEDY THE DEFECT OR
      NONCOMPLLANCE:

      Since these tires were sold only through Discount Tire, tires with the affected DOT serial week
      iden~cation    numbers should be returned to Discount Tire and then forwarded to one of Cooper's regional
      inspection points. All tires returned to Cooper will be inspected for the correct DOT identificationnumber.
      Cooper will.
          1   Replace, mount and balance replacement tires at no charge to the consumer
          1   Render unserviceable (or instruct to render) any tire of the affected bracket that has been placed into
              scrvicc.


 9.   ENCLOSURES, IF ANY (Three copies of all notices, bulletins and other communications that were sent
      to more than one distributor, dealer or purchaser and relate directly to the defect or noncompliance):
July 10, 2007

Dear Customer:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor
Vehicle Safety Act.

Cooper Tire & Rubber Company has decided that a defect which relates to motor vehicle
safety exists in the tires built from July7, 2002 through March 30, 2005, identified as follows:

LT265/75R16E           Tubeless Radial         Standard Load           Dominator Sport AIT

       Identification numbers:         UPW8XDJ2702 thru UPW8XDJ1305

Cooper Tire & Rubber Company ("Cooper") has determined that the Dominator Sport ATT
LT265175R16 Load Range E tires experienced a higher rate of property damage claims and
adjustments due to belt separations. In some cases the tread may separate from the tire
casing resulting in body damage to the vehicle or in rare cases a vehicle crash. Driving at
highway speeds should be avoided until the tires have been inspected and replaced if they fall
within the identification numbers shown above.

Cooper is recalling all of the tires with the identification number@)above. To insure your
safety and satisfaction with our product, we request that you return the recalled tires and this
letter to your nearest Discount Tire or America's Tire Company store, the exclusive retailer for
this product (call for location 800-774-6560). If there are no such stores in your immediate
area, please call Cooper's Consumer Relations at (800) 854-6288 and you will be directed to
the nearest Cooper-affiliated dealer. If the inspection verifies that you have a tire or tires with
the suspect identification number, they will be replaced, mounted and balanced at no charge to
you if you have presented them for remedy within ninety (90) days after (i) receipt of this letter
or (ii) notice that a replacement tire is available (if not available at the time of inspection). It is
expected that replacement tires will be available at the time of the inspection. However, if the
tires are not available at the time of inspection, they will be available wi,thin twenty-one (21)
 days. After expiration of the ninety (90) day period, tires will be replaced under our normal
 adjustment policy.

The time required to determine if the tire is subject to RECALL is only a few minutes and
approximately thirty (30) minutes per tire if replacement is required.

Should any questions or problems arise while your tires are being inspected or replaced,
please call Cooper's Consumer Relations at (800) 854-6288 and we will be of service to you.
In the event you believe we have failed to or are unable to replace your tire(s) without charge
to you, within the ninety (90) day period described above, you may so notify the Secretary of
Transportation at the following address: Administrator, National Highway Traffic Safety
Administration, Washington, DC 20590, or phone NHTSA's Vehicle Safety Hotline at 888-327-
4236 (TTY 800-424-9153; or go to http://www.safercar.gov).
We regret this inconvenience, but are sure that you understand our interest in your safety and
satisfaction with your tires. Please see your nearest Discount Tire or America's Tire Company
store immediately for free replacement of the recalled tires. Give this letter to them so that it
can be returned to us for purposes of this recall.

Sincerely,



Jeff Schumaker
Director, Quality Systems




                                TO BE COMPLETED BY DEALER

Tires inspected and replaced
                                              (date)

Dealer stamp or name and address




Dealer: Please complete the above, attach letter to the Tire and Tube Claim Form and return
with the recalled tires.
July 10, 2007



Dean Butler
Senior Vice President
Discount Tire Company
20225 North Scottsdale Road
Scottsdale. AZ 85255


Dear Mr. Butler:

Cooper Tire & Rubber Company ("Cooper") has determined that the Dominator Sport NT
LT265175R16 Load Range E tires manufactured between July 7, 2002 and March 31, 2005 and
sold by Discount Tire Company andlor America's Tire Company ("Discount Tire") experienced a
higher rate of property damage claims and adjustments due to belt separations. In some cases
the tread may separate from the tire casing resulting in body damage to the vehicle or in rare
cases a vehicle crash.

      Dominator Sport NT
      Size: LT265175R16 Load Range E
      Tire Identification Numbers: UPW8XDJ2702 through UPW8XDJ1305

Cooper is recalling all of the tires with the identification number(s) above. Effective
immediately, you or your stores must not sell any of the tires listed and described above.

You should comply with the following instructions regarding the return of new and used tires at
no charge in accordance with such provisions.


                     PROCEDURE FOR RETURN AND CREDIT OF TIRES

NEW TIRES:

      All subject new tires existing in your inventory, or in your stores inventories, should be
      returned immediately in one shipment, freight collect to the designated inspection point
      for your area as indicated on the attached map. To assure proper handling, these tires
      should be listed on the attached Returned Goods Form and the form must accompany
      this shipment in the packing slip envelope provided. This envelope must be listed on the
      bill of lading as: "1 envelope - related shipping documents."

       Upon verification by Cooper that the tires returned are within the subject group, we will
       issue credit to you based upon the current invoice price of the tires.
USED TIRES:

     Registration records have been reviewed and consumers who have registered tires with
     the subject identification number(s) are being notified of the recall. Additionally, we will
     notify any consumer who, according to your records, has purchased any of the subject
     tires between July 7, 2002 and March 30, 2006. Attached for your information is a copy
     of the notification being sent to such consumers. Tires removed from consumer vehicles
     as a result of this recall should be replaced with tires of like size and service description
     bearing identification numbers other than those listed above.

     We have advised the consumer to return the subject tire(s) to you along with their recall
     notice letter. If your inspection verifies that the consumer has a tire(s) with the suspect
     identification number, the tire(s) should be replaced, mounted and balanced at no charge,
     if presented for remedy by September 30, 2007. It is expected that replacement tire(s)
     will be available at the time of inspection; however, if the tires are not available at the time
     of inspection, they will be available within twenty-one (21) days.

      For any tires removed from consumer vehicles during this recall, Cooper will authorize an
      allowance of $1 7.50 per tire to cover mounting and balancing.

      YOU ARE PROHIBITED FROM SELLING NEW OR USED TIRES COVERED BY THIS
      NOTIFICATION.

      Tires removed from consumer vehicles must be listed on our standard Tire and Tube
      Claim Form. This claim form must accompany the shipment according to standard
      adjustment procedures.

      For the purpose of this recall, the Claim Form must include the subject tires only. The
      word "RECALL" must be printed directly below the name and address on the claim form.
      All tires should be identified in crayon with the Claim Form reference number per
      standard adjustment procedures.

      Upon verification by Cooper, credit will be issued to you on a no charge replacement
      basis if replaced by you and returned to Cooper on or before October 31, 2007.

you should return all of the subject tires in this recall to the inspection point as indicated on the
attached map. These tires should be classified as SCRAP and shipped as SCRAP RUBBER
TIRES, freight collect. Freight collect privileges apply only within the prescribed time period.
Any tires returned after the designated time will be handled under our regular adjustment
procedures.
If you have any questions pertaining to the implementation of this recall or need assistance,
please contact Cooper's Consumer Relations Department at (800) 854-6288.

Sincerely,



Jeffrey J. Schumaker
Director, Quality Systems


Attachments