Interpretation ID: nht89-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 07/06/89

FROM: LINDA B. KENT -- MARKET DEVELOPMENT SR. ACCOUNT EXECUTIVE FASSON SPECIALTY DIVISION

TO: STEPHEN WOOD -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/09/90 FROM STEPHEN P. WOOD -- NHTSA TO LINDA B. KENT -- FASSON SPECIALTY DIVISION; REDBOOK A35; VSA 108 [A] [2]; STANDARD 205

TEXT: Dear Sir:

Enclosed you will find a brochure and samples of a product called Contra Vision. Avery International has purchased the Marketing and Selling rights of this invention. Contra Vision allows you to print an image on one side of a clear substrate, but from the other side, the viewer can see right through the sign.

This product will be used for promotional signage in store windows, but also has application in rear taxicab windows, as well as rear and side windows of city buses.

I am writing to request clarification of federal vehicle safety compliance standard no. 205. I understand that the federal standards outline the visibility rates that are permissable for use in these types of vehicles at the OEM level. I understand, al so, that there are state standards that can be the same or different from the federal standards. If, though, Contra Vision does comply with the federal standards, I feel that this will greatly help us in approching each state on an individual basis.

I feel that our product does comply with the federal standards in that you can see clearly through the Contra Vision panels. The same amount of ink is on both sides of the panel, it's just that your eye sees the colored dot, yet ignores the black dot.

If you could respond back to me with my request of clarification and your thoughts on compliance, it would be greatly appreciated.

Look forward to hearing from you.

Sincerely, ENCLOSURE