Interpretation ID: nht87-1.4

TYPE: INTERPRETATION-NHTSA

DATE: 01/07/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Joe Rutman -- President, Pathway Ltd.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 2/10/86 letter from Erika Z. Jones to Timothy Pawl (Std. 108)

TEXT:

Mr. Joe Rutman President, Pathway Ltd. P.O. Box 88111 Grand Rapids, MI 49580

This is in reply to your letter of October 16, 1986, with reference to an electronic message display known as "Tellite"

We have reviewed your letter and our letter of February 10, 1986, to Timothy Pawl that you enclosed. The interpretation to provided Mr. Pawl was posited on the fact that Tellite was "in close proximity" to the center highmounted stop lamp which, in the a bsence of further explanation, we assumed meant either to the right or left of it. Your letter, however, indicates that the message function may be superimposed over the center lamp, though operating independently of it. Before we provide a definitive re sponse to your letter of October 16, 1986, we would appreciate your providing us with a photo or drawing of Tellite so that we will have a better understanding of it. We should also like to know what messages it is intended to display.

Sincerely,

Erika Z. Jones Chief Counsel

October 16, 1986

United States Department of Transportation National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

Attention: Erika Z. Jones, Chief Counsel

Dear Ms. Jones:

Pathway Ltd. previously corresponded with you through a potential joint venture party regarding DOT approval of a concept which we now hope to move forward and promptly develop. Pathway has developed an electronic message display known as "Tellite". We b elieve, based on prior correspondence, that the circuitry and display conforms with, or is at least not in violation of, any NHTSA regulations or standards. Please note that this display board will incorporate the red, third brake light located in the re ar window of the vehicle. The circuitry for the red brake light is independent of the message circuitry and overriding. In other words, in the event that the brake is depressed, the third stop light (red LEDs) illuminates and the amber message LEDs are o verridden and are not illuminated during braking. (The amber message board is approximately 4 inches wide and 2 inches high).

It is our intention initially to sell this product as an aftermarket installation. However, we are also interested in pursuing the original equipment manufacturers. The purpose of this letter is to specifically request any direction you might provide reg arding whether our concept, as outlined, fails in any way to comply with any Federal (NHTSA) regulations for installation in the rear window of a passenger vehicle.

You should also know that the amber message board would not flash during display.

I look forward to your response. Please direct any further correspondence to my attention, Joe Rutman, President, Pathway Ltd., P.O. Box 88111, Grand Rapids, MI 49508. Thank you.

Very truly yours

Joe Rutman

(See 2/10/86 letter from Erika Z. Jones to Timothy Pawl)