Interpretation ID: nht91-6.21

DATE: October 14, 1991

FROM: Robert W. Smith -- President, Auto Safety Corporation

TO: Taylor Vinson -- Senior Staff Attorney, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated November, 1991 (est) from Paul Jackson Rice to Robert W. Smith (A38; Std. 108)

TEXT:

My partner and I want to thank you for all the help you gave us during the course of the meeting in your office on August 15, 1990.

Since that meeting we have been continuing the development of our prototype stop lamp license plate frame, in order to conform to all applicable NHTSA standards.

The purpose of this letter is to confirm what we learned at that meeting. Your computer search of Safety Standard #108 data as it would apply to our device, the flashing/steady burning stop lamp, turned up the following:

1. In the case of the Simcox letter (A29, Redbook 3, Erika Z. Jones to Bettie Lou Simcox, October 24, 1986), the use of a flashing/steady burning stop lamp is permissible on a motorcycle. As you'll recall, our embodiment, which complies with specifics of the Safety Standard #108, is a specially designed license plate frame that incorporates a light assembly and a patented (U.S. Patent No. 4,871,945) electronic circuit. (See attached drawings Fig. 1 and Fig. 2)

2. Safety Standard #108 also would allow the use of a flashing/steady burning stop lamp on passenger cars. Specifically, for our purposes, in the embodiment of a license plate frame with built-in lights and circuitry. (Drawing Fig. 1)

3. Safety Standard #108 would permit the use of an auxiliary flashing/steady burning stop lamp which could be mounted on the rear of vans, pickup trucks, and mini vans. (Drawing Fig. 3)

In closing, we again thank you for the help you have given us.

ATTACHMENT

Motor vehicle flashing/steady burning stop lamp license plate frame. (Fig. 1 and Fig. 2) (Graphics omitted)

Auxiliary flashing/steady burning stop lamp. (Fig. 3) (Graphics omitted)