ID: 1919y

Mr. David S. Hughes
3150 W. 4299 So.
West Valley City, UT 84119

Dear Mr. Hughes:

This is in reply to your letter with respect to a lighting fixture you wish to install on your trailer. Your diagram shows it to be a rectangular unit that displays "Thanks Driver" or "Thank You" as a courtesy message. The unit may be mounted on the rear of the trailer, "between the safety bar under the floor of the trailer", or "directly behind the mud flaps." In either location, you state that it "would be out of the way of any regulated light." You are also interested in the possibility of selling the lamp. I regret the delay in responding.

This agency has no authority to "approve" or "disapprove" individual items of lighting equipment. We can, however, advise you as to the relationship of your device to the Federal motor vehicle safety standard on lighting administered by this agency, and the National Traffic and Motor Vehicle Safety Act under which the standard was issued. With respect to your installation of the lamp on your own truck, this agency has no regulations that would govern such an action. The acceptability of this device would be determined under the laws of the individual States in which a vehicle so equipped is registered and operated. We are unable to advise you on State law and recommend that you contact the American Association of Motor Vehicle Administrators for guidance, at 4600 Wilson Blvd., Arlington, Va. 22203.

We assume that your interest in selling the lamp is as an aftermarket accessory to truck owners. If the lamp is installed by the owner of the truck, once again there are no Federal standards that apply to it, only the laws of the individual States. However, if the lamp is installed by a manufacturer, distributor, dealer, or motor vehicle repair business, under Federal law its installation must not render inoperative, either in whole or in part, any of the lighting equipment required by the Federal lighting standard. To aid these parties in avoiding a violation of that prohibition, you should ensure the wiring does not interfere with the effectiveness of the wiring of lamps installed in accordance with Federal requirements. Without a photo, we are unsure of the relationship of the location of the courtesy device in either of the two locations you have suggested to the location of other rear lights required by Federal law, such as identification lamps, clearance lamps, stop lamps, turn signal lamps, etc., though you have stated that it is "out of the way" of them. However, your statement indicates that you recognize the importance of ensuring that the signal from a supplementary lamp not dilute the effectiveness of Federally-required lighting equipment, and we appreciate your concern.

If you have further questions, we shall be pleased to answer them.

Sincerely,

Stephen P. Wood Acting Chief Counsel

/ ref:l08 d:7/24/89

ID: nht72-3.2

DATE: 04/28/72

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: National Tire Dealers & Retreaders Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 5, 1972, concerning the amendment to Motor Vehicle Safety Standard No. 117, published March 23, 1972 (Docket 1-8; Notice 7, 37 F.R. 5950). In your letter you protest against the labeling requirements of the standard. It is not clear from your letter, however, whether you are referring to both the requirements for affixed labels (S6.3.1), or for permanent labeling (S6.3.2), or both, and as a consequence we have treated your comments as referring to the labeling requirements in general.

You state in your letter that retreaders, particularly small retreaders, cannot meet the labeling requirements "on any reasonable and practical basis." You state further that you have demonstrated how the labeling requirements will force retreaders to hire additional personnel, increase production time, and consequently increase the retreaders' cost per tire. You also claim that the labeling issue is a "fairly simple problem" whose solution can be easily found within the statutes.

Congress, in enacting section 201 of the National Traffic and Motor Vehicle Safety Act, made it clear that motor vehicle tires should be permanently labeled with specific items of information dealing with their safe use. The labeling requirements of Standard No. 117 are based on this statutory mandate and do recognize and allow for difficulties retreaders might have in meeting all of the requirements for labeling set forth in section 201. For example, Standard No. 117, in not requiring that the generic name of the cord material or the actual number of plies be included in the labeling information for retreaded tires, recognizes that this information will not be available for some casings which are allowed to be used.

The NHTSA considers the labeling requirements of Standard No. 117 to be both reasonable and practical, and believes they can be met by the overwhelming majority of retreaders, if not all, in an economical manner. Each item of information is now available to the retreader should the need to relabel arise. By using the procedures and technology developed for compliance with the Tire Identification and Recordkeeping regulations (49 CFR Part 574), by combining labeling information on the same label where appropriate, and by careful sorting of casings before retreading, the NHTSA believes that even the smallest retreader can meet these requirements. While the requirements will no doubt cause some changes in existing production techniques, with a possible slowing initially of the production process, there is no reason to believe that these changes, once instituted, will result in significant permanent increases in the costs and time needed for the production of retreaded tires.

Finally, you cite figures showing what you claim is an abnormally high number of retreaded tire manufacturers who have gone out of business in the past year, and ask, "How many more will be lost before we get reasonable and practical and understandable regulations?" We understand your concern for retreading companies that have gone out of business. But since Standard No. 117 has not yet become effective, these closings are obviously not the result of NHTSA regulations.

ID: 1984-2.7

TYPE: INTERPRETATION-NHTSA

DATE: 06/07/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Cibie/Marchal -- G. Couffinhal

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. G. Couffinhal Cibie/Marchal 17, rue Henri Gautier 93012 Bobigny Cedex France

This is in reply to your letter of April 19, 1984, to Richard Van Iderstine of this agency. With respect to the standardized light source socket for replaceable bulb headlamps, you have asked whether a bulb socket design with a "bottom view" diameter of 29.7 mm. etc. would be acceptable.

As you have noted, Dimension P of Figure 3-7 and 3-8 of Standard No. 108 specifies a millimeter dimension of "(28.75 to 28.65)". The dimension of your design exceeds this figure, and is therefore noncompliant with requirements intended to insure proper function with standardized replaceable light sources. It is not permitted by Standard No. 108.

Sincerely,

Frank Berndt Chief Counsel

17, rue Henri Gautier 93012 Bobighy Cedex Telephone (1) 843.93.70 - Telex 210 323 F

N.H.T.S.A. Mr. Richard Van IDERSTINE

Office of Vehicle Safety Standards Room 5307 400 Seventh St., SW WASHINGTON DC 20590 - USA -

Le 19 Avril 1984

Dear Richard

CIBIE requests interpretation concerning the interchangability drawing of the headlamp bulb assembly socket (In reflector) figure 3-7 of the Federal Register - Volume 48 Number 191 - Dated Friday September 30, 1983.

We draw your attention to the bottom view dimension "P" which appears to identify a circle of diameter 28,70 +/- ,005 mm. We would request your opinion about the enclosed drawing dated April 13th 1984 showing three arcs of circle with a diameter of: 29,7 + 1 + 0 mm.

The reason for this request is quite simply in order to obtain a better injection gate in the mould.

This design peculiarity has no effect upon the requirements as laid down by the NHTSA for either the correct installation of the bulb nor the hermeticity of the head light unit.

For information please find enclosed a copy of our drawing E 3277-80 which illustrates the nature of our request.

We would appreciate your interpretation of this matter as soon as possible.

Yours sincerely,

G. COUFFINHAL

COPY: 030 - M. GERARD A36 - M. DORLEANS 039 - Mme THAIN 050 - M. J. MARSHALL

********INSERT GRAPHIC********

COUPE A

ID: nht81-1.49

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Friedman and Medalie

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Leonard A. Fink Attorney at Law Friedman and Medalie 1899 L Street, NW Washington, D.C. 20036

Dear Mr. Fink:

This is in response to your letter forwarding your firrm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

December 4, 198O

Administrator National Highway Traffic Safety Administration 400 Seventh Street, N.W. Washington, D.C. 20590

Attn: VIN Coordinator

Gentlemen:

On behalf of our client, Steyr-Daimler-Puch A.G., and in accordance with FMVSS 115, we furnish the following information regarding the VIN number code to be used by our client:

ID: nht91-4.3

DATE: May 22, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: George D. Powley -- Project Engineer, Truck-Lite Co., Inc.

TITLE: None

ATTACHMT: Attached to letter dated 4-29-91 from George D. Powley to Paul Jackson Rice (OCC 6011)

TEXT:

This responds to your letter of April 29, 1991, with respect to the orientation of electrical contact blades on sealed beam headlamps.

Truck-Lite would like to produce both a large rectangular Type 2B1 sealed beam headlamp and a small rectangular Type 2A1 headlamp using the same blade orientation. Specifically, you would like to use the 2B1 orientation on the 2A1 unit. You do not feel that this would affect adversely the lamp's "ability to interchange with existing lamps in motor vehicles presently in the field."

The basic dimensional requirements for sealed beam headlamps are set forth in SAE Standard J1383 APR85 Performance Requirements for Sealed Beam Headlamps, incorporated by reference in Motor Vehicle Safety Standard No. 108. However, in reference to the Figures of J1383 which set forth the dimensions, "only those dimensions marked 'I' for interchangeability are applicable." (Section S7.3 of Standard No. 108). Our examination of the Figures indicate that the electrical contact blade orientation dimensions for Type 2A headlamps are marked "I", and thus must be met by Type 2A headlamps designed to comply with Standard No. 108. On the other hand, the contact blade orientation dimensions for Type 2B headlamps do not appear to be marked "I", and the manufacturer may depart from the ones indicated without violating Standard No. 108.

This means that you could not use a Type 2B1 blade orientation on a Type 2A1 headlamp as you wish. On the other hand, you could use the Type 2A orientation on the Type 2B, if you find it feasible to do so.

You also indicated that Koito is currently selling Type 2A1 headlamp with a non-standard contact blade orientation. I have forward a copy of this letter to our Office of Vehicle Safety Compliance for appropriate action. Thank you for calling this matter to our attention.

ID: nht69-2.45

DATE: 12/11/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: American Motors Corporation

COPYEE: CLAYBROOK; BOAZ; FULMER; NIELD; ARMSTRONG

TITLE: FMVSR INTERPRETATION

TEXT: We have received your submittal of consumer information in response to the requirements of 49 CFR Part 375. That regulation requires that manufacturers submit their information to the Administrator 30 days in advance of the time it is made available to prospective purchasers. Since we have not required that this advance submittal be in the same form as that given to prospective purchasers, the following comments are only advisory in nature. There are several respects, however, in which your information, if supplied in this form to prospective or actual purchasers, would not satisfy the requirements of the regulations.

1. The Stopping Distance information is presented as a "range of stopping distances," both in numerical and graphical form. The regulations clearly require a single stopping distance figure to be provided for a given group, that can be met or exceeded by all vehicles in the group. We do not know, and consumers surely would not know, the significance of the lower figure given. Even if it were clear, the provision of such additional, non-required information in close proximity to the required data would cause confusion in attempting to compare figures between various makes--the main purpose of the information.

2. The provision of four sets of data in respect to partial failure of the braking system, for "fronts operative" and "rears operative," and for lightly-loaded and maximum-loaded vehicles, is not in accordance with the regulation requirement that information be provided for the "most adverse combination" of weights and system failures. As stated in item 1. above, the inserting of this additional information, self-serving in every case since only the worst element should be included, would make comparisons difficult and be unfair to competing manufacturers who followed the regulations strictly.

3. The form of the Stopping Distance information would fail to satisfy the requirement that the information be presented "in effentially the form illustrated in Figure 1" of 49 CFR @ 375.101. In particular, we refer to the placing of two columns side by side instead of the single-axis graph depicted in that figure, and the inclusion of other varying between the required statements and warnings and the information itself. "The reference to shorter stopping distance with wheel lock-up and without restricting pedal effort, between the required information and the graphs, is especially objectionable, since the safety advantages of avoiding wheel skid were a particular concern in developing this regulation. Although the regulation do not prohibit the provision of other then required information in a Consumer Information booklet, they do require that it be connected in such a manner that the required information, both taxtual and cumulative, is presented in "essentially the form illustrated." 4. The Tire Reserve Load section of the regulations requires that "the table that is provided for a specific vehicle shall contain only information that is applicable to that vehicle." This requirement prohibits a large, all-purpose chart such as yours, with information for many vehicle included on it, at least as far as the information given to the actual purchaser of a vehicle is concerned. More generally, the information is not presented in "essentially the form illustrated in Figure 1" of 49 CFR @ 375.102.

5. The large, all-inclusive bar graph on Accleration and(Illegible Word) Ability does not present the information in "essentially the form illustrated in Figure 1" or 49 CFR @ 375.106, or recuired.

We will be glad to answer any questions that you may have with respect to the requirements of these or other motor vehicle safety regulations and standards.

ID: nht88-2.23

TYPE: INTERPRETATION-NHTSA

DATE: 05/09/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Nolan and Taylor-Howe Funeral Home, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

President Nolan and Taylor-Howe Funeral Home, Inc. 5 Laurel Avenue Northport, NY 11768

Dear Mr. Nolan:

This is in reply to your letter of March 24, 1988, enclosing a letter you have received from the Department of Motor Vehicles, New York State, advising you that your 1987 Cadillac hearse requires a center high-mounted stop lamp. You have asked for the sp ecifications of such a lamp.

The center high-mounted stop lamp is required only on passenger cars. A passenger car is defined as a motor vehicle "designed for carrying 10 persons or less." A "multipurpose passenger vehicle" is one "designed for carrying 10 persons or less which is c onstructed either on a truck chassis or with special features for occasional off road operation." A "truck" is defined as a motor vehicle "designed primarily for the transportation of property or special purpose equipment." The agency recognizes chassis constructed for commercial use, such as a hearse, as the equivalent of a truck chassis. The determination of vehicle category is initially that of the manufacturer or final stage assembler who certifies compliance with all Federal motor vehicle safety st andards applicable to the category of vehicle selected. In our opinion, a hearse could be properly certified as a either a "multipurpose passenger vehicle," or a "truck."

In a conversation with Taylor Vinson of this Office on April 29, you informed us that the first six characters of the VIN of your hearse are "1GEDO9", and that its final stage assembler, Superior, had certified it as an "MPV" (multipurpose passenger vehi cle). The "G" in the VIN identifies it, according to internal documents of the initial stage manufacturer, General Motors, as "Cadillac Incomplete Coaches" (meaning, it would appear, funeral coaches), and the "9" as "Cadillac Commercial Body/Chassis." Th is chassis does not form the basis of any passenger car completed by Cadillac. The letter from New York State states "The manufacturer claims that funeral cars are classified as multipurpose vehicles and do not require the lights." This is correct, as yo u have told us that Superior has classified it as an MPV, and certified its compliance to all standards applicable to that vehicle category. As the center high-mounted stop lamp standard is not one of those applicable to multipurpose passenger vehicles, there is no Federal requirement that your hearse be equipped with such a lamp.

We appreciate your interest in safety, and trust that this answers your question.

Sincerely,

Erika Z. Jones Chief counsel

U.S. Department of Transportation National Highway Traffic Safety Administration Office of Standards Compliance 400 Seventh Street, S.W. Washington, D.C. 20590

RE: 1987 CADILLAC HEARSE AND THIRD BRAKE LIGHT

Gentlemen:

Enclosed please find a copy of the letter we received from the New York State Department of Motor Vehicles dated March 16, 1988. They have determined that the above vehicle should be required to have a third brake light.

I would like to know what the requirements are as to its specific location, size. etc.

Please forward any and all pertinent information regarding the above to this office.

Thank you in advance for your assistance.

Yours truly,

NOLAN & TAYLOR-HOWE FUNERAL HOME, INC. James P. Nolan, Jr. President

JPN:plg ENC:

Mr. James P. Nolan, Jr. Nolan & Taylor-Howe Funeral Home, Inc. 5 Laurel Avenue Northport, L.I., NY 11768

Dear Mr. Nolan:

In your letter dated February 22, 1988, you asked if a third taillight is required on a 1987 Cadillac hearse. The manufacturer claims that funeral cars are classified as multi-purpose vehicles and do not require the lights.

Federal Motor Vehicle Safety Standards require a third brake light on 1986 and newer passenger motor vehicles. Multi-purpose passenger vehicles are exempt from this requirement. A multi-purpose passenger vehicle is a vehicle which is built on a truck cha ssis and has certain features making it suitable for off-road operation. I do not believe a hearse can quality as a multi-purpose passenger vehicle. Therefore, I believe your hearse requires a third brake light.

The Department of Motor Vehicles' has no control over a manufacturer located in another state. I suggest you write to the U.S. Department of Transportation, National Highway Traffic Safety Administration, Office of Standards Compliance, 400 Seventh Stree t, S.W., Washington, D.C. 20590. The National Highway Traffic Safety Administration has the authority to require the manufacturer to recall every vehicle to bring it into conformity with the standards.

I trust this information will be of assistance to you.

Very truly yours,

ARTHUR L. ALOWITZ Assistant Counsel

ID: overbay

Mr. Larry W. Overbay
Director, Automotive and Support
Equipment Directorate
U.S. Department of the Army
U.S. Army Combat Systems Test Activity
Aberdeen Proving Ground, MD 21005-5059

Dear Mr. Overbay:

This letter follows up a telephone conversation between Mr. Edward Glancy of my staff and Mr. John Hretz of the U.S. Department of the Army in which Mr. Hretz requested a clarification of a February 17, 1995, letter that we sent to you. In that letter, we discussed the testing of air braked vehicles under Federal Motor Vehicle Safety Standard (FMVSS) No. 121, Air Brake Systems. We explained that, as a result of a court decision, the emergency stopping test requirements, set forth in S5.7.1 of the standard, are not currently applicable to trucks and trailers.

As Mr. Glancy explained, subsequent to that letter, the National Highway Traffic Safety Administration (NHTSA) issued a final rule reinstating emergency stopping tests in FMVSS No. 121. The amendments reinstating these tests take effect on March 1, 1997, for truck tractors and March 1, 1998, for other medium and heavy vehicles that are equipped with air brakes. Once these amendments take effect, the provisions in S5.7.1 will again be applicable to air braked vehicles.

Mr. Hretz asked whether, in conducting the emergency stopping distance tests, removal of the service air signal line (a non-manifold line which is designed to carry compressed air) from the rear air brake relay valve is considered by NHTSA to be a valid test. Your question is addressed below.

Section S5.7.1 states that

When stopped six times for each combination of weight and speed specified in S5.3.1.1, except for a loaded truck tractor with an unbraked control trailer, on a road surface having a PFC of 0.9, with a single failure in the service brake system of a part designed to contain compressed air or brake fluid (except failure of a common valve, manifold, brake fluid housing, or brake chamber housing), the vehicle shall stop at least once in not more than the distance specified in Column 5 of Table II.

In describing the failure conditions for which stopping distance requirements must be met, S5.7.1 broadly specifies "a single failure in the service brake system of a part designed to contain compressed air or brake fluid," except for certain listed parts. It is our opinion that the failure mode Mr. Hretz described in which one disconnects the service air signal line at the rear service air relay comes within this language. Therefore, a vehicle would not comply with FMVSS No. 121 if it did not meet the specified stopping distance requirements after disconnection of the service air signal line at the rear service air relay.

I hope this information has been helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

cc: Project Manager Family of Medium Tactical Vehicles (FMTV) Attn: SFAE-TWV-FMTV (Hretz) Warren, Michigan 48397-5000

ref:121 d:7/25/95

ID: 86-4.8

TYPE: INTERPRETATION-NHTSA

DATE: 07/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Davis C. Thekkanath

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Davis C. Thekkanath Sr. Supervising Engineer Oshkosh Truck Corporation P.O. Box 2566 Oshkosh, WI 54903-2566

Dear Mr. Thekkanath:

This is in reply to your letter of May 23, 1986, asking for a waiver from compliance with the headlamp mounting height requirements of Motor Vehicle Safety Standard No. 108 with respect to prototype and future production trucks you have developed for military application.

No federal motor vehicle safety standard applies to a vehicle manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications (Title 49 Code of Federal Regulations Sec. 571.7(c)). This means that the headlamps on production models of your military truck may be mounted higher than 54 inches without creating a noncompliance with Standard No. 108. If the truck is also sold for commercial applications, however, it would be required to conform with the 54-inch limitation.

Although the exception quoted above applies to vehicles manufactured for sale, the agency has no objection to limited use on the public roads of nonconforming prototype vehicles that have been developed expressly for sale to the Armed Forces of the United States.

Sincerely,

Erika Z. Jones Chief Counsel

May 23, 1986

Office of Chief Counsel National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C.

SUBJECT: Waiver FMVSS1O8

We are manufacturers of heavy duty vehicles both commerical and military. We have recently developed a new vehicle - our model Z-1838. This will be used as a military cargo transport truck. These trucks have their head- lights located higher than the maximum allowable of 54 inches (FMVSS1O8). This is to protect the lamps from the brush and other objects during cross- country runs. Although we do not have a supply contract for the specific vehicles from the U.S. military at this time, we have built a few prototypes for tests, etc. We would, therefore, request you to exempt these vehicles, both the prototypes and any future production vehicles for the U.S. Government, under the Z-1838 configuration, from the headlight height requirements per FMVSS1O8.

Thank you.

Sincerely,

OSHKOSH TRUCK CORPORATION

Davis C. Thekkanath Sr. Supervising Engineer

DCT:lh

ID: nht90-3.66

TYPE: Interpretation-NHTSA

DATE: August 24, 1990

FROM: Mr. and Mrs. Albert J. Fasel

TO: Arthur H. Neill, Jr. -- Chief, Crash Avoidance Division, Office of Vehicle Safety

TITLE: None

ATTACHMT: Attached to drawing entitled "Eye-Level Turn Signal" (graphics omitted); Also attached to letter dated 9-25-90 from P.J. Rice to Mr. and Mrs. A.J. Fasel (A36; Std. 108); Also attached to copy of Standard No. 111 (text omitted)

TEXT:

Thank you for sending the Rules and Regulations.

In the Safety Standard No. 108, could you give us a positive interpretation that says there is no law or regulation that prohibits turn signals being amber and in no way is an impairment to the function of the center high mounted red stop lamp.

Red is used on a traffic signal and amber is always caution. This idea has been used for years. For 80 years, they used red tail lights exclusively. Not until recently have they incorporated amber into their signals.

On Page 48237, a field test results shows a signal lamp design more effective.

On Page 48239, to Delay Safety Standard No. 108 to await new improvements will result in delay of implementing requirements known to appreciably reduce accidents and save lives.

This draws your attention. You know the vehicle ahead is slowing or stopping, with the addition of the amber turn signals, you would also know if the car is going to turn.

In conclusion we feel the principals that apply to the center high mounted red stop lamp applys to the amber eye-level turn signals and merits this improvement.

Please give this some expert consideration and reply.

Enclosed is a picture. We have a photo-type and to really see its effectiveness it has to be seen in action.

"EYE-LEVEL TURN SIGNAL" Albert J. Fasel - #P3788

ABSTRACT:

This invention relates to automotive turning signals and in particular to a signal that is used in conjunction with the rear bumper signal lights. The signal is mounted in the rear window of the vehicle. Two different models are used. One model for use with an already existing rear window

light or without one. The unit would straddle the already existing light or it comes with a brakelight if there is not one. By using this it aids in seeing the directional in poor weather conditions such as bright sun, rain, snow or fog.

MARKETS & DISTRIBUTION:

Based on the effectiveness, efficiency, safety and convenience, market potential is good. It could be sold through parts & accessories retailers and wholesalers, miscellaneous merchandise stores, department stores and mail order catalogs.

STATUS:

This invention is currently Patent Pending.

This invention now has a Patent No. 4,896,250 issued Jan. 23rd, 1990.