Timothy D. McDonnell, Esq.
Vice President, General Counsel and Secretary
Trailmobile Corporation
Amoco Building, Suite 6820
200 East Randolph Drive
Chicago, IL 60601

Dear Mr. McDonnell:

This responds to your request for an interpretation whether a world manufacturer identifier (WMI) assigned to Pullman Trailmobile can continue to be used after Pullman was sold to Trailmobile Corporation, which changed Pullman's name to Trailmobile Trailer Corporation (TTC). Under the facts described below, TTC may continue to use the WMI originally assigned to Pullman.

Your letter states that Pullman Trailmobile, a predecessor of TTC, was assigned the WMI "1PT." In 1991, TTC (as Pullman Trailmobile) was sold to Trailmobile Corporation. Today, TTC is still a division of Trailmobile, and manufactures trailers.

In a telephone conversation with Dorothy Nakama of my staff, you explained that Trailmobile is a holding company, does not manufacture motor vehicles, and is not assigned a WMI. You stated that Trailmobile does not intend to merge TTC into Trailmobile, but to keep TTC as a separate division, and to advertise Trailmobile Trailers Corporation as a trade name. You also stated that Trailmobile will continue to be responsible for trailers manufactured in the past with the WMI "1PT."

NHTSA's regulation at 49 CFR Part 565 Vehicle Identification Number Requirements states that the WMI shall "uniquely identify the manufacturer, make and type of the motor vehicle if its manufacturer produces 500 or more motor vehicles of its type annually." (49 CFR section 565.6(a)) In past interpretation letters, NHTSA has interpreted "uniquely identify" to mean that the same WMI cannot be used for two corporate entities if there is a possibility the two entities will be confused.

The facts of your case are similar to those in a March 20, 1997 letter to Monaco Corporation (copy enclosed). As was the case in Monaco, in your case, no WMI is assigned to the parent company (Trailmobile), but a division (TTC) has a WMI. NHTSA was assured in the Monaco case that there are no plans for the parent company, Monaco, to manufacture motor vehicles (which would require assigning a WMI). Similarly, you assure us that since it is a holding company, Trailmobile Corporation itself will not manufacture motor vehicles. You have also assured us that TTC will remain a separate division, and advertised as a trade name.

Because the relevant facts in your case and Monaco's are the same, we arrive at the same decision in your case as we did in Monaco's. Since Trailmobile itself is not assigned a WMI, but its division, TTC has a WMI, we agree that TTC may continue to use the WMI that was assigned to Pullman. Under the facts described, there would be no confusion as to which corporate entity manufactured the motor vehicle.

A copy of this letter will be sent to the Society of Automotive Engineers (SAE), which has a contract to administer the WMI system for NHTSA. The SAE will make appropriate notations in its records about Trailmobile Corporation and TTC, and may contact you if it needs further information.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

John Womack
Acting Chief Counsel

cc: Ms. Cathy Douds
Society of Automotive Engineers
400 Commonwealth Drive
Warrendale, PA 15096

(Please enclose copy of incoming letter to Ms. Douds also)

Interps: Part 565, Redbook (2)
cc: NCC-20, Subj/chron, DN, NPS, NSA