Interpretation ID: nht92-4.8

DATE: September 14, 1992

FROM: Preston Golder -- Road Reflectors

TO: Legal Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10/5/92 from Paul Jackson Rice to Preston Golder (A-40; Std. 108) and letter dated 4/21/92 from Paul Jackson Rice to Allan Schwartz (Std. 108)

TEXT:

I've been marketing a product for automobiles here in New York State that has become quite popular. I would like to market this product in other states and would first want to find if there were legal problems I might run into. According to the gentlemen I spoke to on the telephone (Mr. Richard Van Iderstine at 202-366-2720) they are not illegal but I should write you to get a written verification of this.

The product is Neon lighting sealed in Lexan plastic with high voltage wires (same as the spark plug wires) extending out of each end. These Neon tubes are sealed and waterproofed at each end of the Lexan. The wires connect in sequence to four of these neon tubes and connect to a power supply that is mounted under the vehicles hood and to the firewall. (enclosed diagram and mounting instructions) They are then connected to a separate toggle switch.

These lights were originally intended for car shows, giving the effect the car was riding on cloud of color.

Young people seeing this effect started purchasing them and a whole new auto accessory was born. They are very popular in both New York and Florida where even neon car clubs have developed.

I was forced to retire two years ago because of a rare lung disease. I soon became bored and as a true entrepreneur soon found a product that even a sagging economy didn't seem to touch. After all most people that buy this product are the young people who are still living at home with mom and pop. They spend their salaries on their vehicles and social life.

I believe this product would do well nationally, however my investors are hesitant because it may be considered illegal in some states, one is California. California with all their car buffs would be a tremendous market for this product.

If you could give me some idea from a Federal standpoint whether we should proceed with trying to market nationally and what problems we may encounter, I would greatly appreciate any help you may be able to give.

I plan on visiting California in November and hope to start marketing this product at that time. I've enclosed several pictures and information.