Interpretation ID: nht88-3.64

TYPE: INTERPRETATION-NHTSA

DATE: 10/05/88

FROM: BYUNG M. SOH -- TARGET MARKETING SYSTEMS INC

TO: TAYLOR VINRON -- OFFICE OF CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/25/89 FROM ERIKA Z. JONES -- NHTSA TO BYUNG M. SOH, REDBOOK A33(6); VSA 108(A)2(A); STANDARD 108; STANDARD 211

TEXT: Dear Sir:

We would like to have your opinion on the enclosed Hub Cap, whether it violates any applicable Federal Motor Vehicle Safety Standards.

It is structured to meet FMVSS No. 571.211. We, however, feel that incorporation of LED's on the hub cap need to be clarified from your office. As described in our press release, the intensity of the LED is maximum 40mmAmp, and it is designed solely fo r cosmetic purpose, not for illuminating purpose.

Your immediate reply would be appreciated.

Thank you.

Sincerely,

Enc.: 1. our press release 2. color photo of product in motion

STARRACE Self-Lighting Hub Cap

What is STARRACE Self-lighting Hub Cap?

A Hub Cap that has a self-contained motion activating generator in the core of the Hub Cap, and made of durable, rust-proof, virgin ABS. Maintenance Free and requires NO special tools or knowledge for installation. This innovative concept is patented i n 18 countries including the U.S.A. Requires NO wiring and can be installed/replaced just a easily as replacing a regular Hub Cap.

How will STARRACE Self-Lighting Hub Cap Work?

STARRACE has 14 LED lights aligned on a linear plane of a hub cap diameter, and self-motion activation generator which could generate a minimum 20 to a maximum 40 mmAmps/LED's depending on the RPM's. Intensity of the LED lights proportionate to the spee d of the vehicle, as it triggers ON/OFF automatically by motion.

Target Market of the STARRACE Self-lighting Hub Caps?

According to our survey, major demographic target market falls in those ages between 18 to 35, male and female, nationwide: People who spend a considerable amount of money for automotive accessories should be a primary target group. The secondary target group could be those who drive major or rural highways daily. An excellent Safety device by enhancing visibility to other driver in addition to its unique cosmetic purpose. Another substantial potential market is a segment of car owners who like to dec orate their cars to distinguish them from others. STARRACE will certainly satisfy ego's of those sectors.