Interpretation ID: aiam2097
Jr.
Walt Robbins
Inc.
6121 Lincolnia Road
Alexandria
Virginia 22312;
Dear Mr. Robbins: This is in response to your letter of June 5, 1975, enclosing a copy o your patent for a tire described as a 'Radial, Bias Ply Tire' and requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires--Passenger Cars*. The tire would be constructed with three full body plies: two bias plies (angle 35 degrees) and on radial ply (angle 90 degrees).; S4.3(g) of the standard requires permanent molding of the word 'radial into or onto both sidewalls if the tire is a radial ply tire and, by implication, prohibits the use of the word 'radial' if the tire is not a radial ply tire. In S3., 'radial ply tire' is defined as:; >>>a pneumatic tire in which the ply cords which extend to the bead are laid at substantially 90 degrees to the centerline of the tread.<<<; The tire you have described is not within the scope of this definitio because it includes ply cords extending to the beads which are not laid at substantially 90 degrees to the centerline of the tread. Therefore, the word 'radial' must not appear on either sidewall.; Sincerely, Frank Berndt, Acting Chief Counsel