Interpretation ID: nht95-3.66

TYPE: INTERPRETATION-NHTSA

DATE: August 2, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Steven Sinkez -- Vice-President, Mitsubishi Motors of America, Inc.

TITLE: NONE

TEXT: Dear Mr. Sinkez:

This responds to your request for an interpretation of our Vehicle Identification Number regulation, which you made in a July 5, 1995, meeting with Dorothy Nakama and Steve Wood of this office. You asked, after Diamond Star Motors Corporation's (DSM's) name is changed to Mitsubishi Motor Manufacturing of America, Inc. (MMMA), whether that company may continue to use the world manufacturer identifier (WMI) assigned to DSM. As discussed below, the answer is yes.

We understand the facts as follows. When DSM was formed, shares of DSM stock were split between Mitsubishi Corporation and Chrysler Corporation. In 1994, Mitsubishi purchased all of Chrysler's shares in DSM. Mitsubishi now owns 100% of DSM stock. Eff ective July 1, 1995, Mitsubishi changed DSM's name to MMMA. We have been informed that no changes other than transfers of shares in DSM stock and the name change were made in MMMA's corporate form.

By way of background information, 49 CFR part 565 Vehicle Identification Number - Content Requirements is intended to simplify VIN information retrieval and to increase the accuracy and efficiency of vehicle defect recall campaigns. Section 565.4(a) prov ides that a portion of the VIN, called the WMI, must "uniquely identify the manufacturer."

The basic issue raised by your question is, if MMMA continues to use the WMI assigned to DSM, whether the WMI will "uniquely identify the manufacturer." In the factual situation at issue, only the company's name is changed, and not the identity of the ma nufacturer, i.e., MMMA is the same corporation as DSM. Therefore, MMMA may continue to use the WMI assigned to DSM.

I hope this response is helpful. If there are any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.