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NY F84506





March 31, 2000

CLA-2-90:RR:NC:MM:114 F84506

CATEGORY: CLASSIFICATION

TARIFF NOS.: 9102.12.80, 9102,12.40, 8524.39.40, 8471.80.90

Ms. Karen E. Kelly
Casio, Inc.
570 Mt. Pleasant Avenue
Dover, New Jersey 07801

RE: The tariff classification of the Casio PC Unite Wrist watch with infrared adapter and software from Thailand

Dear Ms. Kelly:

In your letter dated March 15, 2000 you requested a tariff classification ruling on the Casio PC Unite, model number BZX-20-1SCR.

The Casio PC-Unite is a battery-operated wrist watch with a liquid crystal display (LCD). The watch features time and alarm functions. The watch also contains a 4-bit CPU with 24KB data memory. It functions as a PIM (personal information management) viewer. An infrared adapter and PC link software are available.

The infrared adapter and the PC link software allow the user to download schedules, lists of things to do, contact lists and text data from a computer or a PDA (personal digital assistant). The PC-Unite also allows you to download existing Microsoft Outlook PIM data. Additionally, two separate PC-Unite watches can exchange data with each other.

The PC link software is on a CD-ROM. Note 6 to chapter 85 states that “records, tapes and other media of heading 8523 or 8524 remain classified in those headings, whether or not they are entered with the apparatus for which they are intended.” The PC link software appears to contain the necessary characteristics required for classification in heading 8524.

The applicable subheading for the Casio Unite PC wrist watch will be 9102.12.80, Harmonized Tariff Schedule of the United States (HTS), which provides for wrist watches, other than those of heading 9101, electrically operated, whether or not incorporating a stop watch facility, with opto-electronic display only, other . The rate of duty will be free.

The applicable subheading for the watch band for the Casio Unite PC wrist watch will be 9102.12.40, Harmonized Tariff Schedule of the United States (HTS), straps, bands or bracelets entered with watches of subheading 9102.12.80 and classifiable therewith pursuant to additional U.S. note 2 to this chapter, all the foregoing whether or not attached to such watches at the time of entry, other . The rate of duty will be free.

The applicable subheading for the PC link software will be 8524.39.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for records, tapes and other recorded media for sound or other similarly recorded phenomena, other, for reproducing representations of instructions, data, sound and image. The rate of duty will be free.

The applicable subheading for the infrared adapter will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other units of automatic data processing machines, other. 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 Barbara Kiefer at 212-637-7058.

Sincerely,

Robert B. Swierupski
Director,

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