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NY N009841




May 18, 2007

CLA-2-84:RR:E:NC:1:120

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.9000, 8471.60.9050

Mr. Joseph A. Steele
Partner, Bridgemate US, LLC
350 Sawmill Creek Drive
Nellysford, VA 22958-8025

RE: The tariff classification of the Bridgemate server set from the Netherlands and the Bridgemate terminal set from the China

Dear Mr. Steele:

In your letter dated April 16, 2007 you requested a tariff classification ruling.

The merchandise under consideration is the Bridgemate Pro Scoring System. The system includes a server (made in the Netherlands) boxed with a power adapter (made in China), and a Universal Serial Bus (USB) converter (made in China). It also may be sold with five tournament director keys and one bridge communication cable (25 pin connector, 2.1 mm plug with resister to plug into the back of the terminal). Separately imported is the Bridgemate terminal with keypad (made in China) boxed with four batteries. The system communicates with a personal computer (PC), not under consideration.

The server receives power from the power adapter, and is connected to a PC via a serial port using the USB converter, if necessary. The server contains firmware, non-volatile storage, and a radio transceiver, which communicates wirelessly with the various Bridgemate terminals.

The Bridgemate terminals sit on the players’ card tables. A bridge contract is agreed upon by the players before each hand is played (tricks). One pair will play the hand and the other pair will defend. e.g., A player will bid to make 3 spades; the result is whether they make it. The table number, board, bid and results of each hand of bridge are keyed into the Bridgemate terminal, and transmitted to the server. The server does not do any calculating function. Its firmware stores a table that links a score to every possible bridge contract (bid and result) combination. The server responds to the terminal with the score for each hand. The terminal displays that score per table, board, and player.

A PC, which is not an item subject to this ruling, uses scoring software downloaded from American Contract Bridge League to create the shell of the Bridge Scoring Program and interface with the downloaded Bridgemate software. The Bridgemate software periodically (every few seconds) interrogates the server to retrieve the table number, board, bid and results sent from the terminals. It uses this information to calculate the scores independent from the server. It calculates several hands of bridge and compares the scores. The PC does not send the calculated scores or comparisons to the server or the terminals.

The Bridgemate server is boxed with a power adapter and a Universal Serial Bus (USB) converter, which converts signals from analog to digital. These items are put up in a set for retail sale together, or with five tournament director keys and one bridge communication cable. In either case, the essential character of the set(s) would be exemplified by the Bridgemate server. The server is a composite machine. The principal function of which is an automated data processing machine (ADP) unit. It is of a kind principally used in an ADP system. It is connectable to the central processing unit via a USB converter. It is able to accept or deliver data in a form which can be used by the ADP system. Although the server has certain subsidiary functions, such as volatile storage, and a transceiver, it is not itself "essentially a storage or transceiver unit." The server does perform ADP data acquisition from the terminal, conversion and transmission to the PC to optimize the PC scoring system. The server would meet the definition of other units of an ADP system as per Legal Note 5 (C) to Chapter 84 of the HTSUS.

The Bridgemate terminal is boxed with a keypad and four batteries and put up in a set for retail sale. Noting GRI 3 (b), the essential character of this set would be exemplified by the Bridgemate terminal. The Bridgemate terminal would meet the definition of a “unit" of an automated data processing (ADP) system as per Legal Note 5 (C) to Chapter 84 of the Harmonized Tariff Schedule of the United States, (HTSUS). This set would be classified as other input units of an ADP system.

The applicable subheading for the Bridgemate server set will be 8471.80.9000, HTSUS, which provides for Automatic data processing machines and units thereofOther units of automatic data processing machines: Other: Other. The rate of duty will be free.

The applicable subheading for the Bridgemate terminal set will be 8471.60.9050, HTSUS, which provides for Automatic data processing machines and units thereof: Input or output units, whether or not containing storage units in the same housing: Other: Other: Other. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Denise Faingar at 646-733-3010.

Sincerely,

Robert B. Swierupski
Director,

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