Interpretation ID: nht94-3.84

TYPE: INTERPRETATION-NHTSA

DATE: August 1, 1994

FROM: Richard Quigley -- Special Consultant, Ill Eagle Helmet Company

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attachment dated 8/18/94: Letter from John Womack to Richard Quigley (Std. 218)

TEXT: I have reviewed your letter of July 15, 1994, and have come to some conclusions regarding your apparent confusion concerning the "DOT" symbol I sent to you for your approval, and your subsequent emphatic rejection of same.

Let me see if I understand. You are rejecting my "D" on the basis that the computer bitmapped the letter "D" in transmission to your fax machine, so the right side, therefore, had the appearance of "jagged lines at the top and bottom of the letter th at meet in a straight line parallel to the line that forms the left side of the 'D'"; and our letter "O" on the basis that our letter "O" was not a letter "O", but rather just a circle - or a symbol resembling a circle. Have I got that?

I thought everybody had seen "The letter 'O'" segment of Sesame Street: "To make the letter 'O', (just) draw a circle." Big Bird wouldn't lie.

From that lesson, and/or a little common sense, a common person would be led to conclude that sometimes a circle is just a circle, and sometimes its the letter "O". But, our letter "O" isn't a letter "O", its just a circle . . . right? How does that work?

I think you may have been confused by the fact that I had superimposed the name of our company -- "THE ILL EAGLE HELMET COMPANY" -- inconspicuously around the surface of the letter "O", and had placed our unimposing logo in the center of same. How el se could you have been led to the mistake of believing that our letter "O" was just a circle?

So, here is a another version (this time with the bitmapped "D" smoothed out) for you to show around the office. Ask your people if they read it to say "DOT"? The surveys we have taken (our tests) indicate that virtually everybody sees our version o f a "DOT" sticker for just what it is, a "DOT" sticker.

So, other than the problem with our letter "D" (now corrected), and the fact that you were mistaken about our letter "O", do you have any remaining objections to our use of this sticker on helmets that we have certified as being in compliance with FMV SS 218?

If not, we will proceed on the basis that your silence means consent, and thank you for your response.