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NY C82230




December 9, 1997

CLA-2-84:RR:NC:1:110 C82230

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.9090

Mr. Joseph D. Arruda
A.T. Cross Company
Lincoln, Rhode Island 02865

RE: The tariff classification of a PC Tablet from Hong Kong.

Dear Mr. Arruda:

In your letter dated November 26, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves a PC (personal computer) Tablet which is known as the Cross Pad. This PC tablet is designed to operate as a cordless pointing device.

A low power Radio Frequency (RF) signal is broadcast from the Cross Pad pen to the digitizing Cross Pad tablet through a traditional pad of paper. The pad of paper is transparent to the RF signal at the same time you write on the pad with ink. The Cross Pad PC tablet, just like the pen receives this RF signal. Once received by the Cross Pad tablet, this signal is decoded and transformed into coordinates that are stored as "digital ink" inside the device. This Cross Pad PC tablet is battery powered and portable. After taking notes on the Cross Pad tablet, the user can upload this "digital ink" to a computer program running on a personal computer via a RS-232 serial port connection. Once on the computer, this "digital ink" appears as an exact "electronic carbon copy" of whatever the user wrote.

The Cross Pad PC tablet appears to incorporate the design characteristics which are similar to the input units used with automatic data processing (ADP) applications. Noting Legal Note 5(B) to Chapter 84 of the Harmonized Tariff Schedule (HTS), the Cross Pad PC tablet would meet the definition of a "unit" of an ADP system. This Cross Pad PC tablet also appears similar to the PC Tablet noted in NY Ruling Letter B82861.

The applicable subheading for the Cross Pad PC tablet will be 8471.60.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for other input or output units of automatic data processing machines and units thereof. 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,

Robert B. Swierupski
Director,

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