Interpretation ID: nht75-2.7

DATE: 11/03/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Walt Robbins, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 5, 1975, enclosing a copy of your patent for a tire described as a "Radial, Bias Ply Tire" and requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars. The tire would be constructed with three full body plies: two bias plies (angle 35 degrees) and one radial ply (angle 90 degrees).

S4.3(g) of the standard requires permanent molding of the word "radial" into or onto both sidewalls if the tire is a radial ply tire and, by implication, prohibits the use of the word "radial" if the tire is not a radial ply tire. In S3., "radial ply tire" is defined as:

a pneumatic tire in which the ply cords which extend to the beads are laid at substantially 90 degrees to the centerline of the tread.

The tire you have described is not within the scope of this definition because it includes ply cords extending to the beads which are not laid at substantially 90 degrees to the centerline of the tread. Therefore, the word "radial" must not appear on either sidewall.

SINCERELY,

Walt Robbins Incorporated

June 5, 1975

Mark Schwimmer National Highway Safety Administration Office of Chief Counsel

Enclosed is a copy of our patent #3,672,423. I would appreciate it if you would review this and notify me as to what the labeling requirements would be for the tire construction as shown in this patent, with reference to paragraph S4.3, subparagraph h, of MVSS100. As I interpret your labeling requirements, the radial designation would be adequate as this is a full radial ply. In addition to the radial ply, we have two bias plies, so my question to you is should this be designated radial or radial/bias.

I would appreciate an answer as soon as possible inasmuch as we have completed DOT testing and are ready for production. Your cooperation in this matter will be most appreciated.

VENTURE TIRE CORP.

Walter C. Robbins, Jr. President

United States Patent

Duduk

[15] 3,672,423

[45] June 27, 1972

[54] RADIAL, BIAS PLY TIRE

[72] Inventor: Alexander Duduk, 2300 S 24th Road Apt. #731, Arlington, Va 22206

[22] Filed: April 7, 1970

[21] Appl. No.: 26,411

Patent Omitted.