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Interpretation ID: aiam0372

Mr. Ray Thoman, President, 707 Tire Service, Inc., 5901 Courtesy Lane, Shreveport, LA (sic); Mr. Ray Thoman
President
707 Tire Service
Inc.
5901 Courtesy Lane
Shreveport
LA (sic);

Dear Mr. Thoman: This is in reply to your letter of June 15, 1971, concerning the Tir Identification and Record Keeping Regulation (49 CFR Part 574).; As stated in the interpretation published in the *Federal Register* o May 28, 1971, under section 113(f) of the National Traffic and Motor Vehicle Safety Act, 'it is the tire manufacturer who has ultimate responsibility for maintaining the records of first purchasers'.; Under the Act and the Regulation, we have no authority to require tire manufacturer to choose someone as his designee. I have asked Goodyear's counsel for their position with regard to the possible use of tire dealers customer's lists and was forwarded a letter dated June 8, 1971, from the Goodyear Tire and Rubber Company which sets forth the company's policy with regard to the prohibition in the regulation. I enclose the letter for your information.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel