Comment from Manuel De la Morena de Castro

Re: FMVSS No. 135 — NPRM Docket No. NHTSA-2026-0728 Dear Sir or Madam: I am Manuel de la Morena de Castro, co-owner of U.S. Patent No. 11,338,727 B2, relating to a dynamic and proportional system for signaling vehicle braking maneuvers. I respectfully submit this comment to bring to NHTSA's attention the existence of a patented and independently validated technology that may be relevant to the Agency's consideration of braking and external vehicle signaling in the context of Automated Driving Systems (ADS). TECHNICAL CONSIDERATION As vehicle automation develops, including vehicles in which longitudinal vehicle control may be performed without continuous human operation of conventional driving controls, an important technical consideration arises concerning the relationship between actual vehicle deceleration and external brake signaling. In particular, vehicle deceleration may result from different braking and control mechanisms, including friction braking, regenerative braking and automated longitudinal control. This raises the question of how external brake signaling should reliably communicate the vehicle's actual deceleration behaviour when conventional brake-pedal actuation is not necessarily the sole source of vehicle deceleration. RELEVANT PATENTED TECHNOLOGY U.S. Patent No. 11,338,727 B2 describes a dynamic brake signaling system that uses vehicle deceleration and/or vehicle speed information to control lighting elements in a progressive and proportional manner, providing an external visual representation of vehicle braking behaviour. The technology is designed to operate independently of conventional manual brake-pedal actuation and is intended to provide additional information to following road users regarding the evolution and intensity of vehicle deceleration. The patented technology has been independently evaluated under controlled testing conditions, with documented improvements in driver reaction time. The technology forms part of an international patent family, including granted rights in Europe, China and Japan. RELEVANCE TO ADS AND ELECTRIFIED VEHICLES The technical approach described in U.S. Patent No. 11,338,727 B2 may be relevant to the development of future vehicle architectures in which: vehicle deceleration may occur without direct manual brake-pedal actuation; regenerative braking contributes materially to vehicle deceleration; automated systems control longitudinal vehicle motion; and the external communication of vehicle braking behaviour becomes increasingly important for the understanding and safety of surrounding road users. The broader international regulatory development concerning Automated Driving Systems and external vehicle communication further demonstrates the growing importance of this technical area. CONSIDERATION FOR FUTURE REGULATORY DEVELOPMENT I respectfully encourage NHTSA to consider, as part of its ongoing and future regulatory and technical work, whether brake signaling requirements for automated and electrified vehicles should take into account: the actual longitudinal deceleration of the vehicle; the source of such deceleration, including regenerative and automated braking; the relationship between vehicle deceleration and external brake signaling when conventional pedal actuation is absent or not representative of the vehicle's actual braking behaviour; and whether dynamic or proportional signaling may provide following road users with additional information regarding the intensity and evolution of vehicle deceleration. The purpose of this submission is not to request that NHTSA mandate any particular patented technology or technical implementation. Rather, I wish to ensure that the Agency is aware that an existing, patented and independently validated technology addressing dynamic communication of vehicle deceleration is available for consideration as NHTSA evaluates the future regulatory framework applicable to automated and electrified vehicles. I would be pleased to provide NHTSA with additional technical information regarding the technology and its independent validation should the Agency consider such information relevant to its ongoing work. Respectfully submitted, Manuel de la Morena de Castro Co-owner, U.S. Patent No. 11,338,727 B2 SBS Smart Brake Lighting System ww.dynamicstoplamp.com +34 636 991 610 Spain