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NY R01316




February 9, 2005

CLA-2-84:RR:NC:1:110 R01316

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000, 8471.80.9000

Ms. MaryAnn Sias
UPS Supply Chain Solutions
1515 W. 190 Street (Suite 300)
Gardena, CA 90248

RE: The tariff classification of ViewSonic WMG80 Wireless Media Gateway and the ViewSonic WMA100 Wireless Media Adapter from Taiwan

Dear Ms. Sias:

In your letter dated, January 14, 2005, you requested a tariff classification ruling on behalf of ViewSonic Corporation.

The merchandise under consideration is the ViewSonic WMG80 Wireless Media Gateway and the ViewSonic WMA100 Wireless Media Adapter. The WMG80 (80GB) Wireless Media Gateway allows you to create a wireless local area network (WLAN) for your home or office. With it you can share a single high-speed broadband connection, files, printers and other peripherals between all your computers. It includes two USB ports for external printers and additional storage connectivity. The WMG80 Wireless Media Gateway features a 80GB hard drive and an internal print server. However, it will not directly connect to the Internet. This requires a DSL or cable modem. PCs are connected to the gateway either by cable to a RG45 port or wirelessly by a USB wireless adapter (not include).

The WMG80 Wireless Media Gateway has two major functions: as a LAN switch/router and as a storage device. As it meets Chapter 84, Note 5(B), it is considered to be a unit of an automatic data processing (ADP) machine. The WMG80 Wireless Media Gateway acts as a WLAN device and as a storage server. While this is a multi-function machine under Section XVI, Note 4, no principle function is evident. Therefore, classification will be in accordance with GRI 6 and GRI 3(c) under the subheading that occurs last in numerical order among those which equally merit consideration.

The ViewSonic WMA100 Wireless Media Adapter is used to connect a PC or gateway to a monitor, display, TV or Stereo. It receives, translates and transmits TCP/IP streaming content from the PC into a video or audio format that is compatible with the receiving device. As it meets Chapter 84, Note 5(B), it is considered to be a unit of an ADP machine. It also appears to meets E.N. 84.71(I)(D) with regard to “Signal converting units.”

The applicable subheading for the WMG80 Wireless Media Gateway will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for “[a]utomatic data processing machines and units thereof[o]ther units of automatic data processing machines: [c]ontrol and adapter units.” The rate of duty will be free.

The applicable subheading for the WMA100 Wireless Media Adapter will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “[a]utomatic data processing machines and units thereof[o]ther units of automatic data processing machines: [o]ther: [o]ther.” 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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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