ID: nht94-8.40

DATE: January 26, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tilman Spingler -- Robert Bosch GmbH

TITLE: None

ATTACHMT: Attached to FAX dated 12/6/93 from Tilman Spingler to Chief Counsel, NHTSA

TEXT:

We have received your FAX of December 6, 1993, titled "Petition for an 'Exemption for Inconsequential Noncompliance'" with paragraph S7.8.5.2 of Motor Vehicle Safety Standard No. 108. We have also received your FAX of January 14, 1994, in which you seek to withdraw your petition because "we did not realize that it is allowed to use scales without any identification of the markings."

While it is true that the graduations need not be marked, a noncompliance with Standard No. 108 will exist if the spacing of the graduations is not in accordance with Standard No. 108. In your December FAX petitioning for an inconsequentiality determination, you have asked for "permission to use scales with graduations of 0.2/0.4 degree." This indicates that a noncompliance exists, as Standard No. 108 specifies that graduation spacing be not greater than 0.19/0.38 degree. As we explain later in this letter, Bosch is not the proper person to file an inconsequentiality petition. However, Bosch may submit a petition for rulemaking to change paragraph S7.8.5.2.

The regulatory requirements to which you refer occur at S7.8.5.2(a)(1)(i) and (a)(2)(i). The graduation increment specified is based on the need to provide an increment consistent with the laws of the States pertaining to correct aim. The increment corresponds to 1 inch at 25 feet; State aiming laws typically specify aim measurements in whole inches at 25 feet. These paragraphs relate to requirements that must be met by a component of those headlamp systems that are capable of being aimed by equipment installed on a vehicle. This component is called a "Vehicle Headlamp Aiming Device", or "VHAD." Section S3 defines a VHAD in pertinent part as "motor vehicle equipment permanently installed on a motor vehicle by the manufacturer of the vehicle...." Because the VHAD is installed by the vehicle manufacturer, we regard the vehicle manufacturer as responsible for correction of any noncompliance in the VHAD even if the VHAD were manufactured by another person such as Bosch.

If Bosch has manufactured a VHAD whose specifications do not comply with those of S7.8.5.2, Bosch should notify any vehicle manufacturer to whom it has sold the VHAD so that that manufacturer may have information upon which to make a formal determination of noncompliance and to notify this agency in accordance with 49 CFR Part 573. If the vehicle manufacturer wishes to petition the agency for a determination that the noncompliance of the VHAD is inconsequential as it relates to motor vehicle safety, the agency will proceed to consider the petition after the manufacturer has notified the agency pursuant to Part 573. Because Bosch is under no legal obligation to correct a noncompliance caused by the VHAD that the manufacturer has installed on the vehicle, Bosch is not the proper party to file such a

petition.

The only effect of granting an inconsequentiality petition is that the vehicle manufacturer is excused from its obligation to notify purchasers and to remedy the noncompliance. The granting of the petition does not effect an amendment of the standard. Thus, the grant does not entitle the petitioner to continue to install a VHAD that does not meet S7.8.5.2(a)(1)(i) and (a)(2)(i) of Standard No. 108.

ID: nht94-1.29

TYPE: Interpretation-NHTSA

DATE: January 26, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tilman Spingler -- Robert Bosch GmbH

TITLE: None

ATTACHMT: Attached to FAX dated 12/6/93 from Tilman Spingler to Chief Counsel, NHTSA

TEXT:

We have received your FAX of December 6, 1993, titled "Petition for an 'Exemption for Inconsequential Noncompliance'" with paragraph S7.8.5.2 of Motor Vehicle Safety Standard No. 108. We have also received your FAX of January 14, 1994, in which you seek to withdraw your petition because "we did not realize that it is allowed to use scales without any identification of the markings."

While it is true that the graduations need not be marked, a noncompliance with Standard No. 108 will exist if the spacing of the graduations is not in accordance with Standard No. 108. In your December FAX petitioning for an inconsequentiality determina tion, you have asked for "permission to use scales with graduations of 0.2/0.4 degree." This indicates that a noncompliance exists, as Standard No. 108 specifies that graduation spacing be not greater than 0.19/0.38 degree. As we explain later in this letter, Bosch is not the proper person to file an inconsequentiality petition. However, Bosch may submit a petition for rulemaking to change paragraph S7.8.5.2.

The regulatory requirements to which you refer occur at S7.8.5.2(a)(1)(i) and (a)(2)(i). The graduation increment specified is based on the need to provide an increment consistent with the laws of the States pertaining to correct aim. The increment cor responds to 1 inch at 25 feet; State aiming laws typically specify aim measurements in whole inches at 25 feet. These paragraphs relate to requirements that must be met by a component of those headlamp systems that are capable of being aimed by equipmen t installed on a vehicle. This component is called a "Vehicle Headlamp Aiming Device", or "VHAD." Section S3 defines a VHAD in pertinent part as "motor vehicle equipment permanently installed on a motor vehicle by the manufacturer of the vehicle...." Because the VHAD is installed by the vehicle manufacturer, we regard the vehicle manufacturer as responsible for correction of any noncompliance in the VHAD even if the VHAD were manufactured by another person such as Bosch.

If Bosch has manufactured a VHAD whose specifications do not comply with those of S7.8.5.2, Bosch should notify any vehicle manufacturer to whom it has sold the VHAD so that that manufacturer may have information upon which to make a formal determination of noncompliance and to notify this agency in accordance with 49 CFR Part 573. If the vehicle manufacturer wishes to petition the agency for a determination that the noncompliance of the VHAD is inconsequential as it relates to motor vehicle safety, th e agency will proceed to consider the petition after the manufacturer has notified the agency pursuant to Part 573. Because Bosch is under no legal obligation to correct a noncompliance caused by the VHAD that the manufacturer has installed on the vehic le, Bosch is not the proper party to file such a

petition.

The only effect of granting an inconsequentiality petition is that the vehicle manufacturer is excused from its obligation to notify purchasers and to remedy the noncompliance. The granting of the petition does not effect an amendment of the standard. Thus, the grant does not entitle the petitioner to continue to install a VHAD that does not meet S7.8.5.2(a)(1)(i) and (a)(2)(i) of Standard No. 108.

ID: nht69-1.45

DATE: 09/11/69

FROM: AUTHOR UNAVAILABLE; H. M. Jackin for W. M. Jacklin, Jr.; NHTSA

TO: Hon. W. Proxmire - U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 27, 1969, to the Director, Legislative Liaison, Department of Transportation, concerning Mr. Eugene J. Shermeister's comments on headlamps for motor vehicles.

Enclosed for Mr. Shermeister's information is a copy of Federal Motor Vehicle Safety Standard No. 108 on lighting requirements for the vehicles specified in the standard. Standard No. 108 is applicable to new vehicles manufactured on or after the effective date of January 1, 1969. In accordance with the National Traffic and Motor Vehicle Safety Act of 1966, the initial safety standards were based on existing standards. Headlighting requirements, as specified in Standard No. 108, were therefore based on existing Bureau of Motor Carrier Safety Regulations, certain State regulations and the Society of Automotive Engineers (SAE) Standards. On this basis, Standard No. 108 specifies that headlamps for all vehicles except motorcycles conform to SAE Standards J579a and J580a, entitled, respectively, "Sealed Beam Headlamp Units for Motor Vehicles" and "Sealed Beam Headlamp." To provide protection from blinding effects to oncoming drivers, SAE Standard J579a specifies a maximum lamp output of 37,500 candlepower. This candlepower value is considerably less than the candlepower output of quartz iodine type headlamps.

As indicated in paragraph S2 of Standard No. 108, the standard is applicable to lighting on new vehicles and not to replacement lighting equipment. Except for vehicles subject to the Bureau of Motor Carrier Safety Regulations, the requirements for replacement lighting equipment, as well as lighting requirements for vehicles in use, are those requirements as set by the regulatory agencies of the individual states.

The National Highway Safety Bureau is sponsoring a research contract on improved forward lighting for motor vehicles. Results of this contract will not only provide us with well-founded data for use in amending the standard, but will also assist us in evaluating the relative merits of sealed beam, quartz iodine and other types of headlamps.

ENCLOSURE

ID: 8998

`

Mr. Joe de Sousa President Safety Pro's International, Inc. 34126 State Road 54 West Zephyrhills, FL 33543

Dear Mr. de Sousa:

We have received your letter of August 12, 1993, as well as your letter to Mr. Van Iderstine of this agency and its enclosures.

You are interested in marketing an accessory daytime running lamp (DRL) system, and have asked for an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to this product. There appear to be two versions of this system. In both systems, the DRLs are the lower beam headlamps, automatically activated at 77% intensity when the ignition is turned on. The taillamps and side marker lamps are not activated. The systems are deactivated when the ignition is turned off. The systems differ in that one automatically activates the headlamps to full intensity (while activating the taillamps and side marker lamps as well) at a pre- determined lower ambient light level.

Under the National Traffic and Motor Vehicle Safety Act, aftermarket lighting equipment may be installed provided that it does not render inoperative, in whole or in part, any device or element of design installed in accordance with a Federal motor vehicle safety standard. The system you describe is congruent with the DRL systems permitted by Standard No. 108, which allows DRLs to be lower beam headlamps operated at less than full intensity, without activation of the taillamps and side marker lamps. Therefore, the installation of either of your DRL systems would not affect a vehicle's pre-existing compliance with Standard No. 108 or any other standard, and is permissible under our regulations.

We note that the reduced intensity is achieved by a "pulse with modulation" which cycle the headlamps "on and off faster than the eye can detect." S5.5.10(d) of Standard No. 108 requires headlamps to be steady-burning for uses other than flashing. While a modulating headlamp technically is not a steady-burning one, for purposes of this requirement we have concluded that there is no failure to conform if the modulating light from the lamp is perceived to be a steady beam, as appears to be the case here.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:3/10/94

ID: 0216

Mr. Joe Kover
463 West Creekside Lane
Kaysville, UT 84037

Dear Mr. Kover:

This responds to your letter of July 25, 1994, to Jere Medlin of this agency. You have presented several questions regarding an electric circuit that you have designed for use in motor vehicles, and which you call a Light Control Unit (LCU).

The LCU automatically turns off the headlamps and tail and parking lamps when the ignition is turned off if the lamps have been activated. The LCU also automatically turns on the headlamps and the tail and parking lamps whenever the windshield wipers are turned on. If the LCU fails when the lights are on, a Light Bus Monitor will automatically restore them.

You have the following questions:

"Would a motor vehicle operator be in violation of the federal motor vehicle safety standards by maintaining both the head and tail/park lights on during the hours of daylight?"

No. The Federal motor vehicle safety standards do not tell an owner when it is or is not permissible to use safety equipment.

"Does the LCU meet the federal motor vehicle safety standards? Could the LCU be integrated into the light system of new production vehicles or currently registered vehicles;"

The Federal motor vehicle safety standard on lighting, Standard No. 108, does not apply to supplementary lighting devices such as the LCU. The LCU is permissible on new vehicles provided it does not impair the effectiveness of lighting equipment required by the standard. We do not see that it has this effect. It is permissible to be installed on currently registered vehicles by manufacturers, distributors, dealers or motor vehicle repair businesses provided that it

does not make inoperable any part installed in accordance with a Federal motor vehicle safety standard. We do not see that the LCU has this effect either.

You have also told us that the LCU may be used to operate lamps as Daytime Running Lamps (DRLs) by maintaining the light switch in the on position when the wiper switch has been turned off. One feature of this function is that the LCU "allows the operator to turn off either the head lights only or both the head lights and tail/park lights via the light switch." Your question is "If the operator should elect to employ the LCU as a DRL unit does it meet the federal motor vehicle safety standards?"

Under Standard No. 108, a DRL system is a system of any pair of lamps on the front of a vehicle (other than parking lamps or fog lamps) that is automatically activated and that is automatically deactivated when the operator places the headlamp control in the on position. Further, DRLs can be lower beam headlamps operated at full voltage. Assuming that the LCU turns the lower beam headlamps on rather than the upper beam ones, your system would function as a DRL meeting the requirements of Standard No. 108 when the lower beam headlamps are automatically activated by the windshield wipers and deactivated by turning off the ignition. However, the feature that allows the headlamps to be turned off manually (whether or not simultaneously turning off the parking lamps and taillamps) is not part of a DRL system as specified by Standard No. 108.

Your final request is that we "include the federal specifications for electronic devices." We are unsure what you mean by this as we have no "specifications for electronic devices." I enclose a copy of S5.5.11 of Standard No. 108, the DRL specifications.

Sincerely,

Philip R. Recht Chief Counsel

Enclosure ref:108 dL10/14/94

ID: nht94-4.52

TYPE: INTERPRETATION-NHTSA

DATE: October 14, 1994

FROM: Recht, Philip R. -- Chief Counsel, NHTSA

TO: Kover, Joe

TITLE: NONE

ATTACHMT: Attached To A Letter Dated 7/25/94 From Joe Kover To Jere Medlin (OCC 10216)

TEXT: This responds to your letter of July 25, 1994, to Jere Medlin of this agency. You have presented several questions regarding an electric circuit that you have designed for use in motor vehicles, and which you call a Light Control Unit (LCU).

The LCU automatically turns off the headlamps and tail and parking lamps when the ignition is turned off if the lamps have been activated. The LCU also automatically turns on the headlamps and the tail and parking lamps whenever the windshield wipers ar e turned on. If the LCU fails when the lights are on, a Light Bus Monitor will automatically restore them.

You have the following questions:

"Would a motor vehicle operator be in violation of the federal motor vehicle safety standards by maintaining both the head and tail/park lights on during the hours of daylight?"

No. The Federal motor vehicle safety standards do not tell an owner when it is or is not permissible to use safety equipment.

"Does the LCU meet the federal motor vehicle safety standards? Could the LCU be integrated into the light system of new production vehicles or currently registered vehicles;"

The Federal motor vehicle safety standard on lighting, Standard No. 108, does not apply to supplementary lighting devices such as the LCU. The LCU is permissible on new vehicles provided it does not impair the effectiveness of lighting equipment require d by the standard. We do not see that it has this effect. It is permissible to be installed on currently registered vehicles by manufacturers, distributors, dealers or motor vehicle repair businesses provided that it does not make inoperable any part i nstalled in accordance with a Federal motor vehicle safety standard. We do not see that the LCU has this effect either.

You have also told us that the LCU may be used to operate lamps as Daytime Running Lamps (DRLs) by maintaining the light switch in the on position when the wiper switch has been turned off. One feature of this function is that the LCU "allows the operat or to turn off either the head lights only or both the head lights and tail/park lights via the light switch." Your question is "If the operator should elect to employ the LCU as a DRL unit does it meet the federal motor vehicle safety standards?" Under Standard No. 108, a DRL system is a system of any pair of lamps on the front of a vehicle (other than parking lamps or fog lamps) that is automatically activated and that is automatically deactivated when the operator places the headlamp control in the on position. Further, DRLs can be lower beam headlamps operated at full voltage. Assuming that the LCU turns the lower beam headlamps on rather than the upper beam ones, your system would function as a DRL meeting the requirements of Standard No. 108 when the lower beam headlamps are automatically activated by the windshield wipers and deactivated by turning off the ignition. However, the feature that allows the headlamps to be turned off manually (whether or not simultaneously turning off the p arking lamps and taillamps) is not part of a DRL system as specified by Standard No. 108.

Your final request is that we "include the federal specifications for electronic devices." We are unsure what you mean by this as we have no "specifications for electronic devices." I enclose a copy of S5.5.11 of Standard No. 108, the DRL specifications.

(ENCLOSURE OMITTED.)

ID: nht94-7.46

DATE: March 10, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Joe de Sousa -- President, Safety Pro's International, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/12/93 from Joe de Sousa to NHTSA Office of Chief Counsel (OCC-8998) and letter dated 8/12/93 from Joe de Sousa to Richard Van Iderstine

TEXT:

We have received your letter of August 12, 1993, as well as your letter to Mr. Van Iderstine of this agency and its enclosures.

You are interested in marketing an accessory daytime running lamp (DRL) system, and have asked for an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to this product. There appear to be two versions of this system. In both systems, the DRLs are the lower beam headlamps, automatically activated at 77% intensity when the ignition is turned on. The taillamps and side marker lamps are not activated. The systems are deactivated when the ignition is turned off. The systems differ in that one automatically activates the headlamps to full intensity (while activating the taillamps and side marker lamps as well) at a predetermined lower ambient light level.

Under the National Traffic and Motor Vehicle Safety Act, aftermarket lighting equipment may be installed provided that it does not render inoperative, in whole or in part, any device or element of design installed in accordance with a Federal motor vehicle safety standard. The system you describe is congruent with the DRL systems permitted by Standard No. 108, which allows DRLs to be lower beam headlamps operated at less than full intensity, without activation of the taillamps and side marker lamps. Therefore, the installation of either of your DRL systems would not affect a vehicle's pre-existing compliance with Standard No. 108 or any other standard, and is permissible under our regulations.

We note that the reduced intensity is achieved by a "pulse with modulation" which cycle the headlamps "on and off faster than the eye can detect." S5.5.10(d) of Standard No. 108 requires headlamps to be steady-burning for uses other than flashing. While a modulating headlamp technically is not a steady-burning one, for purposes of this requirement we have concluded that there is no failure to conform if the modulating light from the lamp is perceived to be a steady beam, as appears to be the case here.

ID: nht94-1.76

TYPE: Interpretation-NHTSA

DATE: March 10, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Joe de Sousa -- President, Safety Pro's International, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/12/93 from Joe de Sousa to NHTSA Office of Chief Counsel (OCC-8998) and letter dated 8/12/93 from Joe de Sousa to Richard Van Iderstine

TEXT:

We have received your letter of August 12, 1993, as well as your letter to Mr. Van Iderstine of this agency and its enclosures.

You are interested in marketing an accessory daytime running lamp (DRL) system, and have asked for an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to this product. There appear to be two versions of this system. In both systems, the DRLs are the lower beam headlamps, automatically activated at 77% intensity when the ignition is turned on. The taillamps and side marker lamps are not activated. The systems are deactivated when the ignition is turned off. The systems d iffer in that one automatically activates the headlamps to full intensity (while activating the taillamps and side marker lamps as well) at a predetermined lower ambient light level.

Under the National Traffic and Motor Vehicle Safety Act, aftermarket lighting equipment may be installed provided that it does not render inoperative, in whole or in part, any device or element of design installed in accordance with a Federal motor vehic le safety standard. The system you describe is congruent with the DRL systems permitted by Standard No. 108, which allows DRLs to be lower beam headlamps operated at less than full intensity, without activation of the taillamps and side marker lamps. Th erefore, the installation of either of your DRL systems would not affect a vehicle's pre-existing compliance with Standard No. 108 or any other standard, and is permissible under our regulations.

We note that the reduced intensity is achieved by a "pulse with modulation" which cycle the headlamps "on and off faster than the eye can detect." S5.5.10(d) of Standard No. 108 requires headlamps to be steady-burning for uses other than flashing. While a modulating headlamp technically is not a steady-burning one, for purposes of this requirement we have concluded that there is no failure to conform if the modulating light from the lamp is perceived to be a steady beam, as appears to be the case here.

ID: Webb.1

Mr. Sean P. Webb
6 Oak Hollow Drive
St. Peters, MO 63376

Dear Mr. Webb:

This responds to your May 13, 2004, letter, in which you seek clarification regarding certain provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices and Associated Equipment, related to headlamps. In your letter and in a subsequent phone conversation with Mr. Michael Cole of the Office of Vehicle Safety Compliance, you described perceived problems with your 2003 vehicle, which was purchased new and unmodified. Specifically, you stated that your vehicles halogen headlamps (high beams and low beams) and fog lamps periodically "flicker off and on" or change intensity when activated.

In your letter, you asked whether FMVSS No. 108 requires headlamps to be steady-burning and whether "flickering" of the headlamps would impair the standards minimum illumination requirements. Our response to your questions follows.

The relevant section of FMVSS No. 108 reads as follows:

S5.5.10 The wiring requirements for lighting equipment in use are:

(a)     Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall be wired to flash;
(b)    Headlamps and side marker lamps may be wired to flash for signaling purposes;
(c)     A motorcycle headlamp may be wired to allow either its upper beam or its lower beam, but not both, to modulate from a higher intensity to a lower intensity in accordance with section S5.6;
(d)    All other lamps shall be wired to be steady-burning.

In short, S5.5.10(d) of FMVSS No. 108 requires that all lamps must be steady burning, unless otherwise permitted. The situation that you describe does not appear to fall within any of the exceptions to the steady-burning requirement.

We are unable to comment on the compliance of your specific vehicle with FMVSS No. 108 without conducting independent testing. We note, however, that Mr. Cole confirmed the entry of the information that you provided in the National Highway Traffic Safety Administrations consumer complaints database and provided you with a copy of 49 CFR Part 552, Petitions for Rulemaking, Defect, and Noncompliance Orders, which set forth the procedures for petitioning the agency to examine possible noncompliances or defects in motor vehicles or motor vehicle equipment.

I hope you find this information useful. If you have further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.6/28/04

ID: 77-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 02/11/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Robert Bosch Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 26, 1977, asking for confirmation of several interpretations of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment.

You are correct that, as an equipment standard, Standard No. 108 applies only to replacement of equipment that was originally mounted on the vehicle to enable it to comply with the requirements of the standard. It does not apply to items not covered by the standard, but which are frequently provided as new vehicle options, such as fog lamps and cornering lamps. Any item of lighting equipment not required is permissable to be installed, as you also noted, if it does not impair the effectiveness of the required lighting equipment (paragraph S4.1.3). Additional lighting equipment is otherwise subject to State regulation.

You also asked "what would be the NHTSA's stand on products where SAE standards do not exist, for example halogen headlights?" A halogen headlamp that does not comply with Standard No. 108 and is intended as a replacement headlamp may not be imported and sold for this use. On the other hand, halogen fog lamps may be imported and sold, subject to State regulations.

I hope this answers your questions.

YOURS TRULY,

ROBERT BOSCH CORPORATION

January 26, 1977

Office of Chief Council (N40-30) NHTSA

Re: Federal Motor Vehicle Safety Standard 108

We have inquired at your Chicago District Office regarding FMVSS108. Robert Weltzer of that office has been extremely helpful in providing information and clarifying our questions. He also suggested we contact you for confirmation of a few points and insight into some others.

Robert Bosch is studying the feasibility of marketing a full line of auxilliary and replacement lighting products. As we understand it, FMVSS 108, Section 2, applies 1). only to actual replacement of equipment supplied new with the vehicle. 2). It is also implied that additional equipment which interferes with OE equipment would fall under this regulation. Can you confirm this?

We would interpret this to mean that 108 does not apply to products offered solely as auxilliary, add-on equipment. In practice, however, we realize that most states rely on the recommendations of the AAMVA (American Association of Motor Vehicle Administration) which bases its recommendations on compliance of equipment with SAE standards, usually verified by ETL testing.

What would be the NHTSA's stance on products where SAE standards do not exist, for example, Halogen headlights?

Since no federal law would then apply to such products, are we right in assuming that state laws would prevail, more or less making the AAMVA's approval mandatory?

We are quite interested in literally shedding some light on the confused regulations prevailing in the U.S. for on-highway vehicle lighting. Bosch has some exceptional lighting products which have proven themselves in the European and Canadian markets in particular. We would also like to contribute here to the same safety awareness and concern that our products address themselves to in other countries.

Any insight and comment to the situation at large would be very much appreciated. We are particularly looking forward to your specific reactions to the questions raised in this letter to help guide our marketing decisions for lights.

Allan Cheshire Market Research Analyst