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NY 898478




June 10, 1994

CLA-2-84:S:N:N1:110 898478

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.20.0090; 9817.00

Mr. David A. Manteuffel
American Printing House For The Blind,Inc. 1839 Frankfort Avenue
P.O. Box 6085
Louisville, Kentucky 40206-0085

RE: The tariff classification of a Companion 2000 palm-top computer from New Zealand.

Dear Mr. Manteuffel:

In your letter dated May 24, 1994, you requested a tariff classification ruling.

The merchandise under consideration involves a model Companion 2000 palm-top computer that also incorporates voice capability. The Companion 2000 is more compact than lap-top or note-book computers, and has a keyboard which is slightly smaller than a standard (QWERTY) keyboard. The home row keys can be configured for use as a braille keyboard. This talking computer appears to incorporate many built-in software programs that are developed for use by visually impaired individuals at work, in school, or at leisure.

The monitor for this computer is an LCD display unit, and the files are saved in the MS-DOS format. The Companion 2000 can store up to 1,000,000 characters, and can be connected to external printers, braille embossers, modems, networks, and other computers, through the use of serial and parallel interfaces. The special Text 2000 access software puts in electronic data, a textbook to be downloaded into the computer which can then be heard and/or seen on the screen in large type and/or uploaded to an external device which can print in braille.

The applicable subheading for the Companion 2000 palm-top computer will be 8471.20.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for digital automatic data processing machines, containing in the same housing at least a central processing unit and an input and output unit, whether or not combined. The duty rate will be 3.9 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the applicability of 9817.0096. Your request for a classification ruling should include answers to the following questions:
1. Is the computer, without software, sold to the general public by commercial organizations?
2. Is the software being imported?
3. Is the software installed in the computer prior to importation?

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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