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NY C81161



November 18, 1997

CLA-2-95:D13 C81161

CATEGORY: CLASSIFICATION

TARIFF NO.:9503.90.0045

Mr. Scott Scharton
Thornley & Pitt, Inc.
48 Gold Street
San Francisco, CA. 94133

RE: The tariff classification of the "Create-a-Word Super Mat", made in China.

Dear Mr. Scharton:

In a letter dated October 22 1997 you requested a tariff classification ruling on behalf of your client, Leapfrog, LLC.

A sample of the "Create-a-Word Super Mat" was supplied. This product is a vinyl electronic play mat approximately 39" X 28". This mat is designed to be interactive with children, age Pre K and up. It has grommets built into the upper corners so that the mat may be attached to a wall or similar surface. The front of the mat is brightly colored and has imprinted on it alternating stars and circles. Inside each star or circle is one of the letters of the alphabet. Electronic sensors from each circle or star are connected to a sound module which is powered by 4 "AA" batteries. In operation the child or adult turns the sound module on to one of four functions. The unit will lead the child into various play activities for learning the alphabet either by sight or phonetically. The functions available in the unit are designed to teach the alphabet, teach their phonic sounds, quiz for recognition of the alphabet, quiz for appropriate sounds. It also instructs the child to touch specific letters for spelling certain words, up to sixty, and a program that lets the child independently spell other three letter words. The literature included with your letter indicates that the module has a word memory of approximately four hundred and fifty three letter words.

The applicable subheading for "Create-a-Word Super Mat" will be 9503.90.0045, Harmonized Tariff Schedule of the United States (HTS), which provides for Other toys: Other, Other toys and models. The rate of duty is 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.

Sincerely,

Jeffrey R. Walgreen
Port Director

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