Interpretation ID: nht91-7.13

DATE: 11/16/91

FROM: DAVID M. HART -- PRESIDENT, FLUSHSAVER

TO: PAUL J. RICE -- OFFICE OF CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 12-10-92 FROM PAUL J. RICE TO DAVID M. HART (A40; STD. 108); ALSO ATTACHED TO LETTER DATED 9-3-87 FROM ERIKA Z. JONES TO DAVID M. ROMANSKY (STD. 108)

TEXT: I called NHTSA this date, and after being transferred from department to department, I was advised by a Mr. Roman to write your office.

Our firm specializes in the creation and subsequent marketing of unique patentable products for the mass market.

Our latest is a product which will go by the name FLASHIT, and whose market will be the owners of late model automobiles.

Virtually all late model cars have a third taillight which is located on the package tray in the center of the rear window. The FLASHIT product is essentially a "clear decal", rectangular in shape, which contains a short message. That message for example could be the name of a college (UCLA) or a car rental company, (HERTZ). The word or words contained in the message are not solid print but are clear and become visible when the brake is activated and the red taillight comes on. The red light acts upon the special quality of the product and illuminates the message contained within the "decal". It is essentially no different than the myriad stickers that are currently seen on the rear windows of many cars other than the fact that the message is clearly seen only when the brake light comes on.

Upon investigation we have determined that there is no existing regulation which would prevent the marketing of this product. However since we intend to market the product on a nationwide basis we feel it important to receive feedback from your agency.

Our mailing address is 5440 West Century Blvd. Los Angeles, Ca 90045. Phone 310 670 9939. Your prompt response and assistance would be greatly appreciated.