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Interpretation ID: 2900yy

Mr. Chris Lawrence
Chang & Lawrence
P.O. Box 105-55
Taipei
Taiwan R.O.C.

Dear Mr. Lawrence:

This is in reply to your letter to Dr. Burgett of this agency. Though dated January 5, 1991, we did not receive it until March 7.

With respect to your wish to produce an electronic sign board for installation in the rear window area, or on the rear, of a passenger car, I enclose a copy of an interpretation of this Office dated August 17, l989, regarding such a device. Although the interpretation is restricted to an interior-mounted electronic sign board, our conclusion would not be changed were the device to be mounted on the outside of the rear of the vehicle. In that location, and as an item of original equipment, we believe that it would impair the effectiveness of the required rear lighting equipment by its potential to distract following drivers from the signals sent by the rear lamps when they and the sign board are operated simultaneously. Although the considerations for aftermarket devices are expressed differently, as explained in the August l989 letter, the potential for distraction would appear to create a partial inoperability of the rear lamps within the meaning of the prohibition.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure ref:l08#VSA d:3/2l/9l