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NY L87507




October 6, 2005

CLA-2-84:RR:NC:1:110 L87507

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000; 8473.30.1040; 8473.30.5000

Ms. Jennifer Churchill
Hitachi Computer Products (America), Inc. 1800 E. Imhoff Road
Norman, OK 73071-1202

RE: The tariff classification of TagmaStore AMS500 array storage subsystem components from Japan.

Dear Ms. Churchill:

In your letter dated September 2, 2005 you requested a tariff classification ruling.

Your request concerns five components for the TagmaStore AMS500 RAID (Redundant Array of Independent Disks) subsystem. This subsystem is also known as the DF700M. It is marketed for midrange storage applications. The subsystem uses an enhanced array of inexpensive disks design, which allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. It consists of disk storage units (RKAJ or RKAJAT) and a disk control unit (RKM).

The five components are:
DF700-RKM – Basic Chassis of Rackmount with Standard Accessory DF700-RKAJ – Additional Chassis of Rackmount with Standard Accessory DF-F700-DJ4G2 – 4Gbps Fibre Interface (I/F) Board DF-F700-C1GJ – 1GB Cache Unit
DF-F700-F1JM – Control Unit for RKM

The DF700-RKM Basic Chassis is the control unit for the DF700M series. Its function is to connect with the data source and then send the data to various hard disk drives (HDDs) in the subsystem. It consists of a frame, panel, control unit, backup battery unit, fan assemblies, and power units.

The DF700-RKAJ Additional Chassis is one of the disk storage units for the DF700M series. This frame can hold a maximum of 15 HDDs. As imported it consists of a frame, power units, ENC (subsystem internal interface) unit, ENC cable. It will not be imported with the HDDs.

The DF-F700-DJ4G2 Fibre Interface Board is a 2-port 4 Gbps fibre Interface board with a host connector that allows the DF700-RKM to connect to the data source.

The DF-F700-C1GJ Cache Unit is a 1 Gbyte cache memory module used to increase the speed of the interface between the DF700-RKM and the data source.

The DF-F700-F1JM Control Unit is the RKM controller board. It may be imported as a separate item for replacing a failed board in the DF700-RKM.

The applicable subheading for the DF700-RKM – Basic Chassis of Rackmount with Standard Accessory, DF-F700-DJ4G2 Fibre Interface Board and the DF-F700-F1JM Control Unit will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofOther units of automatic data processing machines: Control or adapter units.” The general rate of duty will be Free.

The applicable subheading for the DF700-RKAJ – Additional Chassis of Rackmount with Standard Accessory will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Partssuitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other.” The general rate of duty will be Free.

The applicable subheading for the DF-F700-C1GJ Cache Unit will be 8473.30.1040, Harmonized Tariff Schedule of the United States (HTS), which provides for “Partssuitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Printed circuit assemblies: Memory modules suitable for use solely or principally with machines of heading 8471.” The general 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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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