Interpretation ID: nht95-1.90

TYPE: INTERPRETATION-NHTSA

DATE: March 7, 1995

FROM: Takashi Tohse -- Quality Assurance Group, Fabricated Glass general Division, ASAHI GLASS CO., LTD

TO: Marvin Show -- Office of Chief Counsel, NHTSA

TITLE: RE: Company ID in logo marks

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO TAKASHI TOHSE (A43; STD. 205)

TEXT: Dear Mr. Shaw;

We have made an inquiry regarding use of plural company Ids in our logo mark for automotive safety glazing materials and requested NHTSA's comments trough Mr. Clarke Harper of the Office of Vehicle Safety Standards. We understand that this matter was re ferred to you for a legal interpretation.

What is the status of your consideration on this matter? Would there by any other clarification necessary on our part?

It would be very much appreciated if you could provide us with some indication on these questions. Enclosed you will find our letter dated February 6th for your reference.

PREVIOUS LETTER:

February 6, 1995

Mr. Clarke Harper Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington DC 20590 U.S.A.

Rf: Company ID in logo marks

Dear Mr. Harper;

My Colleague Mr. M. Ojima in the automotive Glazing Group suggested that I write to you directly so that this matter can be expedited. Should this matter be handled by someone other than you, please refer it to the proper person.

Use of plural company IDs in our logo mark for automotive safety glazing materials is under consideration. It would be appreciated very much if you could provide with your views on the following two cases as to whether they comply with FMVSS 205 concern ing marking of glazing materials.

Case1: Is it permitted to use different kinds of IDs for different grades of products?

Please refer to the attached sheet

Sample 1: Current Asahi Glass logo mark.

Sample 2&3: Draft of secondary IDs.

Case 2: Is it permitted to use a common company ID for all members of our group? For example, for Asahi Glass Co. ltd. and AP Technoglass Company.

Please refer to the attached sheet.

Sample 4: Draft of AGC logo mark.

Sample 5: Current AP Technoglass logo mark.

Both cases mentioned above have Symbol and Item No. AS1, DOT-20, Material No. M354, Trademark LAMISAFE and company IDs.

It is our contention that these comply with FMVSS 205; however, we will await your comments before making any change.

It would be greatly appreciated if you could give your prompt attention to our inquiry.

Yours sincerely,

Takashi Tohse Quality Assurance Group Fabricated Glass General Division Asahi Glass Co., Ltd. 2-1-2 Marunouchi Chiyoda-ku, Tokyo 100 Japan Tel: 3-3218-5789 Fax: 3-3201-5810