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NY A81236




March 22, 1996

CLA-2-84:RR:NC:MA:110 A81236

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000

Mr. Ernest G. Criez
David K. Lindemuth Co., Inc.
240 Valley Drive
Brisbane, CA 94005

RE: The tariff classification of a Thin Net (Cheapernet) module from China

Dear Mr. Criez:

In your letter dated February 23, 1996, on behalf of Seeq Technology, Inc., you requested a tariff classification ruling.

The merchandise under consideration is an encased module that contains circuit components for a complete Thin Net COAX interface and includes an on-board SEEQQ CMOS 83C92C transceiver DC/DC converter and isolation transformer. This device provides a complete local area network interface for a station, without a transceiver cable.

This unit is part of a chipset to provide the basic components for a LAN interface board. The module performs five main functions: transmission; collision detection; monitoring/timing; receiving; and DC/DC converting. These modules would meet the definition of a "unit" of an ADP system, noting Legal Note 5 (B) to Chapter 84 of the HTS. They are indirectly connectable to the central processing unit, are able to accept and deliver data, and appear to have a principal function of effectuating interconnection of a CPU unit to other units of ADP machines, thereby serving "control" and "adaption" functions. For rulings classifying similar merchandise, please note HQ 953921, HQ 957325, and HQ 954695.

The applicable subheading for the Thin Net (Cheapernet) EM2C module will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for ADP control or adaptor units. The rate of duty will be free.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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